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In Bank One Appeal, Seventh Circuit Finds Deference to Service’s Method Warranted Given Peculiar Record and Circumstances  Financial Transactions


Author:  John Ensminger.


Source: Volume 20, Number 02, November/December 2006 , pp.41-45(5)




Journal of Taxation and Regulation of Financial Institutions

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Abstract: 

In JPMorgan Chase & Co., successor in interest to Bank One Corporation v. Commissioner, the Seventh Circuit affirmed in part (fair value is not fair market value; taxpayer’s methodology did not produce fair market values), reversed in part (standard for rejecting Service’s method), and remanded the case for further proceedings (to evaluate the Service’s method under a different standard). The Circuit Court describes the Tax Court’s opinion as “a veritable treatise on interest swaps,” which the Circuit refrains from duplicating.

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