Legal Opinion

Royer's, Inc. v. United States

Court of Appeals for the Third Circuit

Decided April 7, 1959No. 12798_1PublishedCited by 14 opinions

1Opinion of the Court

GOODRICH, Circuit Judge.

This is a suit to recover taxes paid on contributions to an employees’ profit-sharing plan set up by the taxpayer. The District Court decided against him, E.D.Pa.1958, 163 F.Supp. 225, and he seeks our help.

The facts are uncomplicated and undisputed. There is only one point of law and it is as neat as a point of common law pleading before the Hilary rules.

The taxpayer set up his profit-sharing plan for employees under a trust agreement entered into December 27, 1945. The plan became effective in 1946. Under it the plaintiff was required and did make annual irrevocable…

2Cases cited5 opinions

  1. Nashville Milk Co. v. Carnation Co.Supreme Court of the United States · 1958
  2. Safeway Stores, Inc. v. VanceSupreme Court of the United States · 1958
  3. Harry v. Vance, Trustee in Bankruptcy for Frank Melvin Thompson, Bankrupt v. Safeway Stores, Incorporated, a CorporationCourt of Appeals for the Tenth Circuit · 1957
  4. Nashville Milk Company v. Carnation CompanyCourt of Appeals for the Seventh Circuit · 1956
  5. Royer's, Inc. v. United StatesDistrict Court, W.D. Pennsylvania · 1958

3Cited by14 opinions

  1. American Export Lines, Inc. v. United States. New York and Cuba Mail Steamship Company v. United StatesUnited States Court of Claims · 1961
  2. Russell Manufacturing Company v. United StatesUnited States Court of Claims · 1959
  3. Woodson v. CommissionerUnited States Tax Court · 1980
  4. Abell v. United StatesUnited States Court of Claims · 1975
  5. Evans v. DudleyDistrict Court, W.D. Pennsylvania · 1960

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