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Tax Court’s Decision in Bank One Raises More Questions Than It Answers  

Author:  Linda M. Beale.

Source: Volume 21, Number 01, Fall 2003 , pp.3-16(14)

Journal of Taxation of Investments

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Two items dealing with mark-to-market valuations of swaps were released on the same day this spring: the IRS’s advance notice of proposed rulemaking asking for comments on a safe harbor for valuations under section 475, and the decision in Bank One Corporation v. Commissioner regarding the propriety of the valuation methodology for marking swaps to market used by First National Bank of Chicago (FNBC), part of an affiliated group that is the predecessor to Bank One Corporation. Practitioners and industry participants alike had eagerly awaited the release of both items.


Affiliations:  1: University of Illinois College of Law.

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