In the 1967 case of Joint Industry Board of the Electrical Industry et al. v. United States, the Supreme Court ruled on a tax dispute involving pension plans for unionized electrical workers in New York City. The Internal Revenue Service (IRS) had denied tax-exempt status to these plans because they were funded by employer contributions and administered by boards with equal representation from employers and employees, which was seen as violating regulations that prohibited private inurement or benefit. However, the court unanimously held that these pension funds did qualify for tax exemption under Section 501(c)(5) of the Internal Revenue Code since their purpose was providing retirement benefits to members rather than benefiting any particular group or individual associated with its creation or operation. This decision clarified federal law regarding labor unions' ability to establish and manage employee benefit trusts without jeopardizing their non-profit status.

In the dissenting opinion for the case of Joint Industry Board of The Electrical Industry et al. v. United States, it was argued that the majority's decision to uphold a tax on employee annuity plans unfairly penalized workers and their employers who had chosen this form of retirement savings over others. The dissenting justices believed that Congress did not intend to impose such a tax when they enacted legislation governing these types of plans, as evidenced by their subsequent actions to amend the law in question after realizing its unintended consequences. They also felt that there were significant differences between traditional insurance policies and employee annuity plans which warranted different tax treatment under federal law. Therefore, they disagreed with both the interpretation and application of existing statutes by their colleagues in this case.