Logourl black
From our private database of 14,200+ case briefs...

United States v. Basye

United States Supreme Court
410 U.S. 441 (1973)


Facts

Permanente Medical Group (Permanente) was a limited partnership operated by Basye and his partners (partners) (plaintiffs). Permanente entered into a contract with Kaiser Foundation Health Plan (Kaiser), a medical-services membership organization, whereby Permanente agreed to provide medical services to Kaiser’s members. In exchange for the services, Kaiser paid base compensation to Permanente comprised of (1) monthly payments and (2) contributions to a retirement trust. The retirement trust maintained separate tentative accounts for each of its beneficiaries, all of whom were Permanente partner and non-partner physicians. Participating physicians who completed a required minimum period of continuous service and met other requirements could begin receiving trust payments upon retirement. The tentative accounts of physicians failing to meet certain requirements would be forfeited and redistributed among the retirement trust’s other beneficiaries. Under no circumstances could the trust-fund payments be altered or recouped by Kaiser. Neither Permanente nor its partners reported the trust income on their federal tax returns. The federal tax commissioner assessed deficiencies against each of the partners for their proportionate shares of the funds that Kaiser had paid into the trust. The partners paid the assessments and then filed suit against the United States government (government) (defendant) in federal district court, seeking a refund. The district court entered judgment in favor of the partners, and the court of appeals affirmed. The United States Supreme Court granted certiorari.

Rule of Law

Issue

Holding and Reasoning (Powell, 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 97,000 law students since 2011. Some law schools—such as Yale, Vanderbilt, Berkeley, and the University of Illinois—even subscribe directly to Quimbee for all their law students. Read our student testimonials.

  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. Read more about Quimbee.

Here's why 251,000 law students have relied on our case briefs:

  • Written by law professors and practitioners, not other law students. 14,200 briefs, keyed to 189 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.