Legal Opinion

Bank One Corp. v. Comm'r

United States Tax Court

Decided May 2, 2003No. 5759-95; No. 5956-97Published

F, a financial institution, enters into bilateral contracts which are a type of derivative financial product known as interest rate swaps. Most of F's swaps are of the plain vanilla type where one party (first party) agrees to pay to the other party (second party) amounts ascertained as of certain dates by applying a fixed rate of interest to a set notional amount.

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F, a financial institution, enters into bilateral contracts which are a type of derivative financial product known as interest rate swaps. Most of F's swaps are of the plain vanilla type where one party (first party) agrees to pay to the other party (second party) amounts ascertained as of certain dates by applying a fixed rate of interest to a set notional amount. The second party agrees to pay to the first party amounts ascertained as of the same dates by applying a floating rate of interest (e.g., LIBOR rate) to the same notional amount. For purpose of the mark-to-market rule of sec.…

1Opinion of the Court

BANK ONE CORPORATION (SUCCESSOR IN INTEREST TO FIRST CHICAGO NBD CORPORATION, FORMERLY NBD BANCORP, INC., SUCCESSOR IN INTEREST TO FIRST CHICAGO CORPORATION) AND AFFILIATED CORPORATIONS, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Bank One Corp. v. Comm'r

No. 5759-95; No. 5956-97

United States Tax Court

120 T.C. 174; 2003 U.S. Tax Ct. LEXIS 13; 120 T.C. No. 11;

May 2, 2003, Filed

Findings of fact and conclusions of law. Case returned to parties with instructions for further computations.

F, a financial institution, enters into bilateral contracts

which are a type of derivative…

2Cases cited100 opinions

  1. Daubert v. Merrell Dow Pharmaceuticals, Inc.Supreme Court of the United States · 1993
  2. Helvering v. TaylorSupreme Court of the United States · 1935
  3. Lucas v. American Code Co.Supreme Court of the United States · 1930
  4. Bob Jones University v. United StatesSupreme Court of the United States · 1983
  5. Caisse Nationale De Credit Agricole, a French Banking Corporation v. Cbi Industries, Incorporated, a Delaware Corporation, Cross-AppelleeCourt of Appeals for the Seventh Circuit · 1996

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