Ralph Minor (plaintiff) was a physician practicing with the Snohomish County Physicians Corporation (Snohomish Physicians). Minor elected to participate in Snohomish Physicians’ deferred-compensation plan. As a condition to receiving his deferred compensation, Minor agreed to refrain from working for Snohomish Physicians’ competitors and from practicing medicine after retirement. Snohomish Physicians established a trust that purchased retirement-annuity policies to provide for its future obligations under the plan. Snohomish Physicians was the sole beneficiary of the trust. Participants of the plan, including Minor, had no rights to the trust or its assets. The United States Internal Revenue Service (IRS) (defendant) sought to tax Minor on compensation that Minor had earned, but for which payment had been deferred under the plan. Minor paid the tax and then sued for a tax refund in federal district court. The district court held in favor of Minor, ruling that Minor’s contributions to the plan were not taxable in the year that the contributions were were made. The IRS appealed the district court’s ruling.