Capital One Financial Corporation and Subsidiaries v. Commissioner

133 T.C. No. 8

UNITED STATES TAX COURT CAPITAL ONE FINANCIAL CORPORATION AND SUBSIDIARIES, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket Nos. 19519-05, 24260-05. Filed September 21, 2009. P’s subsidiaries, COB and FSB, issued Visa and MasterCard credit cards. Among the various revenues received from the credit card business, COB and FSB earned interchange. Interchange is income earned by an issuer of Visa and MasterCard credit cards which accrues to the issuer each time a cardholder uses a credit card for a purchase. It is almost always calculated as a percentage of the…