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Townsend Industries, Inc. v. United States

United States Court of Appeals for the Eighth Circuit
342 F.3d 890 (2003)


Facts

Townsend Industries, Inc. (plaintiff) paid for a four-day Canadian fishing trip for all of its employees. The trip was not mandatory, but employees were encouraged and often felt pressure to go. The trip included a dinner at which Townsend’s CEO discussed the state of the company. Although there were no other formal business meetings, the employees discussed work throughout the trip. Indeed, the trip was often the venue at which product developers introduced new products to the company’s national sales team. Townsend did not withhold the per-employee cost of the trip as taxable wages. The Internal Revenue Service assessed deficiencies against Townsend for this failure. Townsend paid the deficiencies but then brought suit seeking a refund. The district court ruled that the trip expenses constituted taxable income. Townsend appealed.

Rule of Law

Issue

Holding and Reasoning (Bowman, J.)

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