Capital One Fin. Corp. v. Comm'r
United States Tax Court
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 total purchase plus, in some instances, a small fixed amount.
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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 total purchase plus, in some instances, a small fixed amount. When a cardholder used a credit card to purchase an item from a merchant, the cardholder agreed to pay COB or FSB the full purchase price of the…
1Opinion of the Court
CAPITAL ONE FINANCIAL CORPORATION AND SUBSIDIARIES, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Capital One Fin. Corp. v. Comm'r
Nos. 19519-05, 24260-05
United States Tax Court
133 T.C. 136; 2009 U.S. Tax Ct. LEXIS 28; 133 T.C. No. 8;
September 21, 2009, Filed
Capital One Fin. Corp. v. Comm'r, 130 T.C. 147, 2008 U.S. Tax Ct. LEXIS 11 (2008)
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…
2Cases cited27 opinions
- United States v. AndersonSupreme Court of the United States · 1926
- Thor Power Tool Co. v. CommissionerSupreme Court of the United States · 1979
- Commissioner v. HansenSupreme Court of the United States · 1959
- United States v. General Dynamics Corp.Supreme Court of the United States · 1987
- United States v. Midland-Ross Corp.Supreme Court of the United States · 1965
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