1. Home
  2. Browse Decisions
  3. T.C.
  4. 130 T.C.
  5. 130 T.C. 147 (2008)
 

CAPITAL ONE FIN. CORP. v. COMMISSIONER

Docket Nos. 19519-05, 24260-05.

130 T.C. 147 (2008)

CAPITAL ONE FINANCIAL CORPORATION AND SUBSIDIARIES, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Tax Court.

Filed May 22, 2008.

Attorney(s) appearing for the Case

Jean Ann Pawlow, Elizabeth A. Erickson, Holly K. Hemphill, Kevin Spencer, and Robin L. Greenhouse, for petitioners.

Gary D. Kallevang, James Hill, and Alan R. Peregoy, for respondent.

OPINION

HAINES, Judge:

This case is before the Court on the parties' cross-motions for partial summary judgment filed pursuant to Rule 121.1 The issue for decision is whether section 446(e) prohibits Capital One Bank (COB) and Capital One, F.S.B. (FSB), from changing their treatment of late-fee income from the current-inclusion method (when it accrued under the all events test) to a method which allows late-fee income...

Let's get started

Leagle.com

Welcome to the leading source of independent legal reporting
Sign on now to see your case.
Or view more than 10 million decisions and orders.

  • Updated daily.
  • Uncompromising quality.
  • Complete, Accurate, Current.

Listed below are the cases that are cited in this Featured Case. Click the citation to see the full text of the cited case. Citations are also linked in the body of the Featured Case.

Cited Cases

  • No Cases Found

Listed below are those cases in which this Featured Case is cited. Click on the case name to see the full text of the citing case.

Citing Cases