Keystone Brass Works v. Commissioner
United States Tax Court
1. Petitioner is a manufacturer of plumbing fittings. In 1941, due to the war program, its supply of raw material was restricted and later entirely extinguished. Consequently, petitioner abandoned its business. Almost simultaneously Packard, the only American manufacturer of Rolls-Royce aircraft engines, approached petitioner with the request that it engage in the production of bronze bushings to be used in that engine.
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1. Petitioner is a manufacturer of plumbing fittings. In 1941, due to the war program, its supply of raw material was restricted and later entirely extinguished. Consequently, petitioner abandoned its business. Almost simultaneously Packard, the only American manufacturer of Rolls-Royce aircraft engines, approached petitioner with the request that it engage in the production of bronze bushings to be used in that engine. The specifications demanded by the English designers of the engine provided for an unusual degree of hardness, chilled castings in permanent mold, and very close machine…
1Opinion of the Court
OPINION.
Van Fossan, Judge:
The issue before us is whether or not the petitioner may be granted the benefit of section 721 (a) (2) (C) of the Internal Revenue Code1 because it had abnormal income in the taxable year, of the class set forth in that section, attributable to prior years.2
The picture presented is that of a small but efficient manufacturer of plumbing fittings called upon to produce bronze bushings for Rolls-Royce aircraft engines — under specifications and requirements theretofore wholly unknown to the petitioner. That the new and untried field of operation demanded much…
2Cases cited3 opinions
- W. B. Knight Machinery Co. v. CommissionerUnited States Tax Court · 1946
- Soabar Co. v. CommissionerUnited States Tax Court · 1946
- Ramsey Accessories Mfg. Corp. v. CommissionerUnited States Tax Court · 1948
3Cited by21 opinions
- Ohio Machine Tool Co. v. CommissionerUnited States Tax Court · 1952
- Sprague Electric Co. v. CommissionerUnited States Tax Court · 1961
- Breeze Corps. v. CommissionerUnited States Tax Court · 1951
- General Tire & Rubber Co. v. CommissionerUnited States Tax Court · 1958
- Overland Corp. v. CommissionerUnited States Tax Court · 1964
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