Bank One Corportation (successor in interest to First Chicago NBD Corporation, formerly NBD Bancorp, Inc., successor in interest to First Chicago Corporation) and affiliated corporations, petitioner v. Commissioner of Internal Revenue, respondent

From: United States. Tax Court. Reports | Date: May 1, 2003| Author: | Copyright information

REPORTS OF THE UNITED STATES TAX COURT

Docket Nos. 5759-95, 5956-97. Filed May 2, 2003.

F, a financial institution, enters into bilateral contracts which are a type of derivative financial product known as interest rate swaps. Most of F's swaps are of the plain vanilla type where on e party (first party) agrees to pay to the other party (second party) amounts ascertained as of certain dates by applying a fixed rate of interest to a set notional amount. The second party agrees to pay to the first party amounts ascertained as of the same dates by applying a floating rate of inter est (e.g., LIBOR ...

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