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)
< previous article |next article > |return to table of contents
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.Keywords:
Affiliations:
.