Signet Banking Corporation - Page 1

                                   106 T.C. No. 5                                     


                               UNITED STATES TAX COURT                                


                     SIGNET BANKING CORPORATION, Petitioner v.                        
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      



               Docket No. 7887-92.       Filed February 29, 1996.                     


               Christopher Kliefoth and Ralph I. Petersberger, for                    
          petitioner.                                                                 
               Phillip A. Pillar and Scott D. Anderson, for respondent.               


                    P is in the banking business.  P issued credit                    
               cards.  P charged its credit card holders an annual                    
               membership fee.  The cardholder agreement provided that                
               the fee was paid in consideration of the issuance of a                 
               card and establishment of a credit limit.  The                         
               agreement stated that P could close a cardholder’s                     
               account at any time and that the annual membership fee                 
               was nonrefundable.  P is an accrual method taxpayer.                   







Page:   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