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United States Fourth Circuit


Capital One Financial Corp. v. Commissioner, 10-1788

In an appeal from a judgment of the Tax Court arising from the disallowance of deductions claimed for estimated miles redemption costs and a retroactive change in accounting method for late fees, judgment is affirmed where petitioner can neither retroactively change the method of accounting used to report credit-card late fees so as to reduce its taxable income by about $400,000,000, nor can it deduct the estimated costs of coupon redemption related to its MilesOne credit card program before customers actually redeem those coupons.

Appellate Information

  • Decided 10/21/2011
  • Published 10/21/2011

Judges

  • WILKINSON

Court

  • United States Fourth Circuit

Counsel

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