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AMERICAN EXPRESS CO. v. U.S.

No. 00-5111.

262 F.3d 1376 (2001)

AMERICAN EXPRESS COMPANY and Affiliated Subsidiaries, Plaintiff-Appellant, v. UNITED STATES, Defendant-Appellee.

United States Court of Appeals, Federal Circuit.

Decided August 23, 2001.

Attorney(s) appearing for the Case

Stephen D. Gardner, Kronish Lieb Weiner & Hellman LLP, of New York, New York, argued for plaintiff-appellant. With him on the brief was Phillip Gall.

Steven I. Frahm, Attorney, Tax Division, Department of Justice, of Washington, DC, argued for defendant-appellee. With him on the brief was Richard Farber, Attorney.

Before NEWMAN, GAJARSA, and DYK, Circuit Judges.

DYK, Circuit Judge.

This case presents a simple issue with significant monetary consequences — whether the Internal Revenue Service ("IRS") properly construed the term "services" appearing in Revenue Procedure 71-21, 1971-2 C.B. 549 to exclude annual cardholder payments to American Express for credit commitment, insurance, and luggage tags. We defer to the IRS's reasonable interpretation of its own Revenue Procedure...

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