Court of Appeals for the Fourth Circuit October 21, 2011, 10-1788 (Capital One Financial Corp. v. Commissioner)

Affirmed by published opinion. Judge WILKINSON wrote the opinion, in which Judge NIEMEYER and Judge FLOYD joined.

OPINION

WILKINSON, Circuit Judge:

This case presents two questions, each born of the efforts of Capital One, a credit card issuer, to defer significant tax liability.