United Parcel Service of America, Inc. v. Commissioner (254 F.3d 1014, 2001)

United States Court of Appeals for the Eleventh Circuit 2001-06-20

Citations

Full opinion text

COX, Circuit Judge:

The tax court held United Parcel Service of America, Inc. (UPS) liable for additional taxes and penalties for the tax year 1984. UPS appeals, and we reverse and remand.

I. Background

UPS, whose main business is shipping packages, had a practice in the early 1980s of reimbursing customers for lost or damaged parcels up to $100 in declared value. Above that level, UPS would assume liability up to the parcel’s declared value if the customer paid 25