Court of Appeals for the Eleventh Circuit June 20, 2001, No. 00-12720 (United Parcel Service of America, Inc. v. Commissioner)

lead-opinion

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.