Signet Banking Corporation v. Commissioner of Internal Revenue

How courts have described this case

Verbatim parenthetical descriptions written by other courts when citing this decision. Ranked by citation-network relevance.

• “[T]he bank simply cannot structure the terms of the cardholder agreement to its advantage and then rely on an indeterminate question of Virginia law to evade the federal tax implications thereof.”
• accrual basis bank denied deferral under Rev, Proc. 71-72 of annual membership fees it received from its credit card customer; bank's right to receive nonrefundable fees was not contingent on performance of any service after the year of receipt

Source: CourtListener parenthetical corpus (CC0).