Legal Opinion
American Express Company and Affiliated Subsidiaries v. United States
Court of Appeals for the Federal Circuit
Decided August 23, 2001No. 00-5111PublishedCited by 59 opinions
1Opinion of the Court
DYK, Circuit Judge.
This case presents a simple issue with significant monetary consequences— whether the Internal Revenue Service (“IRS”) properly construed the term “services” appearing in Revenue Procedure 71-21, 1971-2 C.B. 549 to exclude annual cardholder payments to American Express for credit commitment, insurance, and luggage tags. We defer to the IRS’s reasonable interpretation of its own Revenue Procedure that payments for credit are not for services. Although some portion of the annual cardholder payments were made for services, even under the IRS interpretation of the term,…
2Cases cited26 opinions
- Udall v. TallmanSupreme Court of the United States · 1965
- United States v. Mead Corp.Supreme Court of the United States · 2001
- Auer v. RobbinsSupreme Court of the United States · 1997
- Christensen v. Harris CountySupreme Court of the United States · 2000
- Bowles v. Seminole Rock & Sand Co.Supreme Court of the United States · 1945
21 more not listed; retrieve them via the Exa API.
3Cited by59 opinions
- Information Technology & Applications Corporation v. United States, and Rs Information Systems, Inc.Court of Appeals for the Federal Circuit · 2003
- Texas Digital Systems, Inc. v. Telegenix, Inc.Court of Appeals for the Federal Circuit · 2002
- Coltec Industries, Inc. v. United StatesCourt of Appeals for the Federal Circuit · 2006
- Linc Government Services, LLC v. United StatesUnited States Court of Federal Claims · 2010
- Cathedral Candle Co. v. United States International Trade CommissionCourt of Appeals for the Federal Circuit · 2005
54 more not listed; retrieve them via the Exa API.