X

Thank you for sharing!

Your article was successfully shared with the contacts you provided.
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.

 
Reprints & Licensing
Mentioned in a Law.com story?

License our industry-leading legal content to extend your thought leadership and build your brand.

More From ALM

With this subscription you will receive unlimited access to high quality, online, on-demand premium content from well-respected faculty in the legal industry. This is perfect for attorneys licensed in multiple jurisdictions or for attorneys that have fulfilled their CLE requirement but need to access resourceful information for their practice areas.
View Now
Our Team Account subscription service is for legal teams of four or more attorneys. Each attorney is granted unlimited access to high quality, on-demand premium content from well-respected faculty in the legal industry along with administrative access to easily manage CLE for the entire team.
View Now
Gain access to some of the most knowledgeable and experienced attorneys with our 2 bundle options! Our Compliance bundles are curated by CLE Counselors and include current legal topics and challenges within the industry. Our second option allows you to build your bundle and strategically select the content that pertains to your needs. Both options are priced the same.
View Now
July 22, 2024 - July 24, 2024
Lake Tahoe, CA

GlobeSt. Women of Influence Conference celebrates the women who drive the commercial real estate industry forward.


Learn More
September 05, 2024
New York, NY

The New York Law Journal honors attorneys and judges who have made a remarkable difference in the legal profession in New York.


Learn More
September 06, 2024
Johannesburg

The African Legal Awards recognise exceptional achievement within Africa s legal community during a period of rapid change.


Learn More

Our client, a multi-state full-service boutique, is seeking to add an insurance coverage associate or counsel to work closely with one of th...


Apply Now ›

Our client, an Atlanta-based and family-owned commercial construction services firm, has engaged us to identify an in-house attorney for the...


Apply Now ›

The Office of the Special Commissioner of Investigation for the New York City School District ( SCI ) has broad authority to investigate wro...


Apply Now ›
06/27/2024
The American Lawyer

Professional Announcement


View Announcement ›
06/21/2024
Daily Business Review

Full Page Announcement


View Announcement ›
06/14/2024
New Jersey Law Journal

Professional Announcement


View Announcement ›