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JPMORGAN CHASE & CO. v. COM'R OF INTERNAL REVENUE

No. 05-3730, 05-3742.

458 F.3d 564 (2006)

JPMORGAN CHASE & CO., successor in interest to Bank One Corporation, successor in interest to First Chicago NBD Corporation, formerly NBD Bankcorp, Inc., successor in interest to First Chicago Corporation, and affiliated corporations, Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Seventh Circuit.

Decided August 9, 2006.

Attorney(s) appearing for the Case

David M. Schiffman (argued), Sidley Austin, Chicago, IL, for Petitioner-Appellant.

Judith A. Hagley (argued), Department of Justice, Washington, DC, for Respondent-Appellee.

Before FLAUM, Chief Judge, and MANION and WILLIAMS, Circuit Judges.

MANION, Circuit Judge.

JPMorgan Chase & Company ("the taxpayer"), as successor and on behalf of its affiliated corporation First National Bank of Chicago, contests alleged income tax deficiencies assessed for the years 1990-1993. Specifically, the taxpayer and the Commissioner of the Internal Revenue Service ("Commissioner") disagree about how to calculate the fair market value, and thus the proper taxation, of transactions known as "interest swaps." The tax court...

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