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
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