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                    
               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.                   

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