- 3 -
determining that petitioner's method of accounting for prepaid
annual credit card fees does not clearly reflect income.1
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The Stipulation of Facts and the exhibits attached thereto are
incorporated herein by this reference.
Throughout its 1980 taxable year and to the present, Barnett
Banks of Florida, Inc., has been the parent corporation of
various subsidiary bank corporations and nonbank corporations in
Florida. References to petitioner will be to Barnett Banks of
Florida, Inc., and its subsidiaries in the collective.
Petitioner's principal place of business was in Jacksonville,
Florida, at the time it filed the petition in this case. During
1980 and 1981, petitioner computed its taxable income under the
accrual method of accounting, on a calendar year basis.
Petitioner's Credit Card Program
Petitioner began its bank credit card program in 1968.
During 1980 and 1981, and other years not at issue, the
1 The parties agree that petitioner's charitable deductions
for taxable years 1978 and 1981 should be computed after taking
into account all adjustments to petitioner's taxable income made
by respondent and the Court affecting those years; i.e., those
deductions will be determined in the Rule 155 computation
resulting from this opinion. Similarly, the amounts of the net
operating loss carryovers, investment tax credit, and minimum tax
for the years at issue will be computed during the Rule 155
proceedings. Petitioner does not dispute respondent's other
adjustments.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011