United Parcel Service of America, Inc. v. Commissioner

254 F.3d 1014 (2001)

From our private database of 46,500+ case briefs, written and edited by humans—never with AI.

United Parcel Service of America, Inc. v. Commissioner

United States Court of Appeals for the Eleventh Circuit
254 F.3d 1014 (2001)

  • Written by Robert Cane, JD

Facts

The United Parcel Service of America, Inc. (UPS) (plaintiff) reimbursed customers for lost or damaged packages up to $100 in value. UPS had an excess-value program in which UPS assumed liability for a parcel’s declared value over $100 if a customer paid 25 cents per additional $100 in declared value. UPS profited from this practice and claimed the excess-value charges as income on its 1983 tax return. However, UPS restructured the excess-value program for 1984. UPS’s new plan for the excess-value program was to reroute the payments through an overseas subsidiary, Overseas Partners, Ltd., through a series of insurance transactions. The commissioner of the Internal Revenue Service (IRS) (defendant) determined that UPS was deficient in 1984 for the amount of the excess-value charges. UPS petitioned the tax court for a redetermination, and the tax court upheld the commissioner’s determination. UPS appealed to the United States Court of Appeals for the Eleventh Circuit.

Rule of Law

Issue

Holding and Reasoning (Cox, J.)

Dissent (Ryskamp, J.)

What to do next…

  1. Unlock this case brief with a free (no-commitment) trial membership of Quimbee.

    You’ll be in good company: Quimbee is one of the most widely used and trusted sites for law students, serving more than 832,000 law students since 2011. Some law schools even subscribe directly to Quimbee for all their law students.

  2. Learn more about Quimbee’s unique (and proven) approach to achieving great grades at law school.

    Quimbee is a company hell-bent on one thing: helping you get an “A” in every course you take in law school, so you can graduate at the top of your class and get a high-paying law job. We’re not just a study aid for law students; we’re the study aid for law students.

Here's why 832,000 law students have relied on our case briefs:

  • Written by law professors and practitioners, not other law students. 46,500 briefs, keyed to 994 casebooks. Top-notch customer support.
  • The right amount of information, includes the facts, issues, rule of law, holding and reasoning, and any concurrences and dissents.
  • Access in your classes, works on your mobile and tablet. Massive library of related video lessons and high quality multiple-choice questions.
  • Easy to use, uniform format for every case brief. Written in plain English, not in legalese. Our briefs summarize and simplify; they don’t just repeat the court’s language.

Access this case brief for FREE

With a 7-day free trial membership
Here's why 832,000 law students have relied on our case briefs:
  • Reliable - written by law professors and practitioners, not other law students
  • The right length and amount of information - includes the facts, issue, rule of law, holding and reasoning, and any concurrences and dissents
  • Access in your class - works on your mobile and tablet
  • 46,500 briefs - keyed to 994 casebooks
  • Uniform format for every case brief
  • Written in plain English - not in legalese and not just repeating the court's language
  • Massive library of related video lessons - and practice questions
  • Top-notch customer support

Access this case brief for FREE

With a 7-day free trial membership