Flight Attendants Against Ual Offset (Faauo) and United Air Lines, Inc. v. Commissioner of Internal Revenue

POSNER, Chief Judge.

The plaintiff, an association of flight attendants employed by United Air Lines, filed suit in the Tax Court under 26 U.S.C. § 7476 seeking a declaration that the Internal Revenue Service had erred in determining that the conversion of United’s retirement savings plan for flight attendants to a 401 (k) plan had no tax consequences. The association wanted the plan terminated rather than converted and the plan’s assets distributed to the flight attendants, and it believed that this would happen if the new plan was denied the favorable tax status that the original plan had…