Legal Opinion
United Parcel Service of America, Inc. v. Commissioner
Court of Appeals for the Eleventh Circuit
Decided June 20, 2001No. 00-12720PublishedCited by 41 opinions
1Opinion of the Court
COX, Circuit Judge:
The tax court held United Parcel Service of America, Inc. (UPS) liable for additional taxes and penalties for the tax year 1984. UPS appeals, and we reverse and remand.
I. Background
UPS, whose main business is shipping packages, had a practice in the early 1980s of reimbursing customers for lost or damaged parcels up to $100 in declared value.1 Above that level, UPS would assume liability up to the parcel’s declared value if the customer paid 25<t per additional $100 in declared value, the “excess-value charge.” If a parcel were lost or damaged, UPS would process and pay the…
2Cases cited15 opinions
- Gregory v. HelveringSupreme Court of the United States · 1935
- Commissioner v. SunnenSupreme Court of the United States · 1948
- Knetsch v. United StatesSupreme Court of the United States · 1960
- Frank Lyon Co. v. United StatesSupreme Court of the United States · 1978
- George v. Zmuda and Walburga Zmuda v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1984
10 more not listed; retrieve them via the Exa API.
3Cited by41 opinions
- The Black & Decker Corporation v. United StatesCourt of Appeals for the Fourth Circuit · 2006
- Coltec Industries, Inc. v. United StatesCourt of Appeals for the Federal Circuit · 2006
- Stobie Creek Investments LLC v. United StatesCourt of Appeals for the Federal Circuit · 2010
- Klamath Strategic Investment Fund Ex Rel. St. Croix Ventures v. United StatesCourt of Appeals for the Fifth Circuit · 2009
- Stobie Creek Investments, LLC v. United StatesUnited States Court of Federal Claims · 2008
36 more not listed; retrieve them via the Exa API.