Legal Opinion
JPMorgan Chase & Co. v. Commissioner of Internal Revenue
Court of Appeals for the Seventh Circuit
Decided August 9, 2006No. 05-3730, 05-3742PublishedCited by 27 opinions
1Opinion of the Court
MANION, Circuit Judge.
JPMorgan Chase & Company (“the taxpayer”), as successor and on behalf of its affiliated corporation First National Bank of Chicago, contests alleged income tax deficiencies assessed for the years 1990-1993. Specifically, the taxpayer and the Commissioner of the Internal Revenue Service (“Commissioner”) disagree about how to calculate the fair market value, and thus the proper taxation, of transactions known as “interest swaps.” The tax court rejected the accounting methods used by both the taxpayer and the Commissioner to value the interest swaps, crafted a different…
2Cases cited14 opinions
- Lucas v. American Code Co.Supreme Court of the United States · 1930
- Thor Power Tool Co. v. CommissionerSupreme Court of the United States · 1979
- Brown v. HelveringSupreme Court of the United States · 1934
- Commissioner v. HansenSupreme Court of the United States · 1959
- Leon S. Malachinski v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 2001
9 more not listed; retrieve them via the Exa API.
3Cited by27 opinions
- Samueli v. Comm'rUnited States Tax Court · 2009
- Oneida Nation v. Village of Hobart, WisconsinCourt of Appeals for the Seventh Circuit · 2020
- Capital One Fin. Corp. v. Comm'rUnited States Tax Court · 2008
- Bank of N.Y. Mellon Corp. v. Comm'rUnited States Tax Court · 2013
- Chapman Glen Ltd. v. CommissionerUnited States Tax Court · 2013
22 more not listed; retrieve them via the Exa API.