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CAPITAL ONE FINANCIAL CORP. v. C.I.R.

No. 10-1788.

659 F.3d 316 (2011)

CAPITAL ONE FINANCIAL CORPORATION, AND SUBSIDIARIES, Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee. The Clearing House Association L.L.C., Amicus Supporting Appellant.

United States Court of Appeals, Fourth Circuit.

Decided: October 21, 2011.

Attorney(s) appearing for the Case

ARGUED: Jean A. Pawlow , McDermott, Will & Emery, LLP, Washington, D.C., for Appellant. Deborah K. Snyder , United States Department of Justice, Washington, D.C., for Appellee. ON BRIEF: Elizabeth Erickson , Kevin Spencer , McDermott, Will & Emery, LLP, Washington, D.C., for Appellant. John A. DiCicco , Acting Assistant Attorney General, Teresa E. McLaughlin , United States Department of Justice, Washington, D.C., for Appellee. Bruce E. Clark , H. Rodgin Cohen , Diana L. Wollman , David A. Castleman , Sullivan & Cromwell LLP, New York, New York, for Amicus Supporting Appellant.

Affirmed by published opinion. Judge WILKINSON wrote the opinion, in which Judge NIEMEYER and Judge FLOYD joined.

OPINION

WILKINSON, Circuit Judge:

This case presents two questions, each born of the efforts of Capital One, a credit card issuer, to defer significant tax liability. The first question is whether Capital One can retroactively change the method of accounting used to report credit-card late fees on its 1998 and 1999 tax returns in such a fashion as would reduce its taxable income for those years by roughly $400,000,000. The second is whether Capital One can...

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