Signet Banking Corporation - Page 21

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          to anticipate at the end of the taxable year of receipt that a              
          substantially ratable portion of the services will be performed             
          in the next succeeding taxable year”.  Sec. 3.06(b) of Rev. Proc.           
          71-21, supra at 549.  Petitioner argues that most of the services           
          it provides are contingent on whether a cardholder uses a card.             
               We disagree that petitioner qualifies under section 3.06(b)            
          of Rev. Proc. 71-21, supra.  That section applies if a taxpayer             
          receives an advance payment pursuant to an agreement which                  
          requires the taxpayer to perform contingent services on a                   
          continuing basis in order to earn the payment.  Sec. 3.06, Rev.             
          Proc. 71-21, supra.  The cardholder agreement does not require              
          petitioner to perform contingent services of that kind.  It                 
          requires petitioner to issue a card and establish a credit limit.           
          Once petitioner does those things, petitioner may close an                  
          account at any time.                                                        
               Petitioner cites Cozine & Showfety, “Advance Payments for              
          Goods and Services”, 2 Tax Adviser 602 (1971); and Sobeloff, “New           
          Prepaid Income Rules:  IRS Reversal of Position Will Aid Many               
          Taxpayers”, 33 J. Taxn. 194 (1970).  These articles are useful              
          discussions of Rev. Proc. 70-21, 1970-2 C.B. 501, and Rev. Proc.            
          71-21, supra, but they do not give any reason for us to agree               
          with petitioner on the issue in dispute here.                               
               Petitioner points out that respondent has ruled that the               
          merchant discount earned by a bank operating a credit card plan             
          is service income which a cash basis bank should include in                 



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