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Stichting Pensioenfonds Voor de Gezondheid v. United States

United States Court of Appeals for the District of Columbia Circuit

129 F.3d 195 (1997)

Facts

Stichting Pensioenfonds Voor de Gezondheid (the fund) (plaintiff) was a Dutch pension fund organized for the purpose of benefiting hospital workers. After being assessed taxes by the Internal Revenue Service (IRS) (defendant), the fund filed suit for a tax refund, asserting that it was a tax-exempt labor organization under Internal Revenue Code § 501(c)(5). The district court affirmed the tax assessment, granting the IRS summary judgment. The fund appealed.

Rule of Law

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Issue

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Holding and Reasoning (Tatel, J.)

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A "yes" or "no" answer to the question framed in the issue section;
A summary of the majority or plurality opinion, using the CREAC method; and
The procedural disposition (e.g., reversed and remanded, affirmed, etc.).

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