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SIGNET BANKING CORP. v. COMMISSIONER

Docket No. 7887-92.

106 T.C. 117 (1996)

SIGNET BANKING CORPORATION, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed February 29, 1996.

Attorney(s) appearing for the Case

Christopher Kliefoth and Ralph I. Petersberger, for petitioner.

Phillip A. Pillar and Scott D. Anderson, for respondent.

COLVIN, Judge:

Respondent determined deficiencies in petitioner's Federal income tax of $233,464 for 1982, $689,257 for 1983, $1,177,475 for 1984, and $1,529,931 for 1985.

The sole issue for decision is whether annual membership fees petitioner received from its credit card customers are includable in income in the year in which petitioner received them, or whether petitioner may defer the income over a 12...

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