SIGNET BANKING CORP. v. C.I.R.

No. 96-2429.

118 F.3d 239 (1997)

SIGNET BANKING CORPORATION, Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Fourth Circuit.

Decided July 8, 1997.


Attorney(s) appearing for the Case

ARGUED: William L. Goldman, McDermott, Will & Emery, Washington, DC, for Appellant. Teresa Thomas Milton, Tax Division, United States Department of Justice, Washington, DC, for Appellee. ON BRIEF: Christopher Kliefoth, Dianne Suarez-Lasa, McDermott, Will & Emery, Washington, DC, for Appellant. Loretta C. Argrett, Assistant Attorney General, Gilbert S. Rothenberg, Tax Division, United States Department of Justice, Washington, DC, for Appellee.

Before WILKINSON, Chief Judge, and WILKINS and MOTZ, Circuit Judges.


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...

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