Legal Opinion
Signet Banking Corporation v. Commissioner of Internal Revenue
Court of Appeals for the Fourth Circuit
Decided July 8, 1997No. 96-2429PublishedCited by 10 opinions
1Opinion of the Court
Affirmed by published opinion. Chief Judge WILKINSON wrote the opinion, in which Judge WILKINS and Judge MOTZ joined.
OPINION
WILKINSON, Chief Judge:
Signet Banking Corporation challenges the Commissioner’s determination that the bank failed to properly report annual membership fee revenue from its credit card operations in the year it was received. The Tax Court upheld the Commissioner. Signet Banking Corp. v. Commissioner, 106 T.C. 117, 1996 WL 85845 (1996). Signet now appeals, claiming that the fee income represented payment for services provided over the membership year and therefore…
2Cases cited5 opinions
- Commissioner v. Court Holding Co.Supreme Court of the United States · 1945
- Commissioner v. National Alfalfa Dehydrating & Milling Co.Supreme Court of the United States · 1974
- American Automobile Assn. v. United StatesSupreme Court of the United States · 1961
- Schulde v. CommissionerSupreme Court of the United States · 1963
- Signet Banking Corp. v. CommissionerUnited States Tax Court · 1996
3Cited by10 opinions
- American Express Company and Affiliated Subsidiaries v. United StatesCourt of Appeals for the Federal Circuit · 2001
- Jeanne Greene Snowa v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1997
- United States v. BergbauerCourt of Appeals for the Fourth Circuit · 2010
- PSB Holdings, Inc. v. Comm'rUnited States Tax Court · 2007
- American Express Co. v. United StatesUnited States Court of Federal Claims · 2000
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