Legal Opinion
Albertson's, Inc., Petitioner-Appellant-Cross-Appellee v. Commissioner of Internal Revenue, Respondent-Appellee-Cross-Appellant
Court of Appeals for the Ninth Circuit
Decided December 5, 1994No. 91-70380, 91-70381PublishedCited by 43 opinions
1Opinion of the Court
REINHARDT, Circuit Judge:
On December 30, 1993, we filed an opinion concerning various disputes between Albertson’s and the Internal Revenue Service. 38 F.3d 1046 (9th Cir.1993). We granted the government’s petition for rehearing as to Part II.B of the opinion, which concerned the appropriate tax treatment of deferred compensation agreements. Today we vacate Part II.B of the original opinion and affirm the Tax Court’s decision.
I. BACKGROUND
Deferred compensation agreements (“DCAs”) are agreements in which certain employees and independent contractors (“DCA participants”) agree to wait a…
2Cases cited6 opinions
- United States v. American Trucking AssociationsSupreme Court of the United States · 1940
- Bob Jones University v. United StatesSupreme Court of the United States · 1983
- International Telephone and Telegraph Corporation v. General Telephone & Electronics Corporation and Hawaiian Telephone CompanyCourt of Appeals for the Ninth Circuit · 1975
- Albertson's, Inc. v. CommissionerUnited States Tax Court · 1990
- Brooks v. DonovanCourt of Appeals for the Ninth Circuit · 1983
1 more not listed; retrieve them via the Exa API.
3Cited by43 opinions
- Bosley Medical Institute, Inc., a Delaware Corporation, and Bosley Medical Group, S.C., an Illinois Corporation v. Michael Steven KremerCourt of Appeals for the Ninth Circuit · 2005
- Booth v. CommissionerUnited States Tax Court · 1997
- Bank One Corp. v. Comm'rUnited States Tax Court · 2003
- Samueli v. Comm'rUnited States Tax Court · 2009
- Fazi v. CommissionerUnited States Tax Court · 1995
38 more not listed; retrieve them via the Exa API.