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JPMorgan Chase & Co. v. Commissioner of Internal Revenue

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ARGUED MAY 29, 2008

Before FLAUM, MANION, and EVANS, Circuit Judges.

This case concerns the taxation of JPMorgan’s income from swap transactions. JPMorgan tried to carve out and defer a part of this income for certain costs and expenses associated with the swaps. The Commissioner of the Internal Revenue Service (“Commissioner”), and ultimately the Tax Court, concluded that these income deferrals were not proper, and that JPMorgan’s valuation methodology did not clearly reflect income. JPMorgan then appealed the Tax Court’s decision to this Court, and we remanded the case so that the Tax Court could apply a more deferential standard of review to the Commissioner’s valuation methodology. After the proceedings below were again decided in the Commissioner’s favor, JPMorgan now appeals here for a second time. On this appeal, JPMorgan does not contest the income deferral and valuation issues-it only disputes certain computations regarding the amounts of these carve-outs. Because we find no error in the Tax Court’s acceptance of the Commissioner’s computations, we affirm.

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