Sherwin-Williams Company, Employee Health Plan Trust, Keybank, N.A. Trustee v. United States

OPINION

BOYCE F. MARTIN, JR., Circuit Judge.

Sherwin-Williams Company, Employee Health Plan Trust, Keybank, N.A. Trus tee, appeals the district court’s award of summary judgment in favor of the United States on the Trust’s claim for a refund of claimed overpayment of federal income taxes. For the reasons that follow, and for those expressed in the district court’s well-reasoned opinion, we AFFIRM.

I

The facts of this case are generally undisputed. The Trust is a Voluntary Employees’ Beneficiary Association, which is exempt from federal income tax pursuant to sections 501(a) and 501(c)(9) of the…