Offner Products Corp. v. Renegotiation Board
United States Tax Court
Held: 1. Research and development expenses incurred in 1954 are not allocable to petitioner's renegotiable business. 2. Advertising expenses incurred in 1954 are not allocable to renegotiable business. 3. Petitioner's profits for 1954 were not excessive.
1Opinion of the Court
Dawson, Judge:
The Renegotiation Board determined that petitioner’s profits on renegotiate contracts for the manufacture and sale of electronic jet engine fuel controls to Hamilton Standard Division of United Aircraft Corp., amounting to $205,257.01 for the fiscal year ended December 31,1954, were excessive to the extent of $75,000.
The issue for decision is whether the profits derived by petitioner from the sales of electronic jet engine fuel controls were excessive to the extent determined by the Renegotiation Board in light of the statutory factors for determining excessive profits as set…
2Cases cited6 opinions
- Oscar F. Collins v. New York Central System, a Body CorporateCourt of Appeals for the D.C. Circuit · 1963
- Boeing Co. v. Renegotiation BoardUnited States Tax Court · 1962
- Vaughn Machinery Co. v. Renegotiation BoardUnited States Tax Court · 1958
- Martin Mfg. Co. v. Renegotiation BoardUnited States Tax Court · 1965
- North American Aviation, Inc. v. Renegotiation BoardUnited States Tax Court · 1962
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3Cited by4 opinions
- Mason & Hanger-Silas Mason Co. v. United StatesUnited States Court of Claims · 1975
- Finney v. CommissionerUnited States Tax Court · 1980
- Wott v. CommissionerUnited States Tax Court · 1986
- Offner Products Corp. v. Renegotiation BoardUnited States Tax Court · 1968