List & Clark Constr. Co. v. Renegotiation Board
United States Tax Court
Renegotiation -- Jurisdiction -- Method of Accounting. -- Petitioner returned income on the basis of completed contracts. The Renegotiation Board denied exemption of a contract for excavation at a dam and determined that petitioner realized excessive profits.
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Renegotiation -- Jurisdiction -- Method of Accounting. -- Petitioner returned income on the basis of completed contracts. The Renegotiation Board denied exemption of a contract for excavation at a dam and determined that petitioner realized excessive profits. Held: 1. The Tax Court is without jurisdiction to review the Board's denial of exemption under section 106(a)(6), Renegotiation Act of 1951, as relating to national defense. 2. Petitioner's claim for exemption under section 106(a)(3) denied. 3. Petitioner's method of accounting for income did not properly reflect its costs of the…
1Opinion of the Court
Tietjens, Judge:
Tlie Renegotiation Board determined that the petitioner realized excessive profits of $50,000 in the calendar year 1954 from contracts subject to the Renegotiation Act of 1951. The petitioner denies that any excessive profits were realized and challenges the Board’s determination that the particular contract involved was not exempt from renegotiation. By amendment to the answer the Board asks a determination by the Court that the petitioner’s excessive profits were not less than $150,000. The profits relate to a single contract carried out in 1952 and for which final payment…
2Cases cited4 opinions
- H. E. Harman Coal Corp. v. CommissionerUnited States Tax Court · 1951
- Commissioner of Internal Revenue v. H. E. Harman Coal CorpCourt of Appeals for the Fourth Circuit · 1952
- Vaughn Machinery Co. v. Renegotiation BoardUnited States Tax Court · 1958
- Golbert v. Renegotiation BoardUnited States Tax Court · 1957
3Cited by2 opinions
- Perry v. United StatesUnited States Court of Claims · 1975
- List & Clark Constr. Co. v. Renegotiation BoardUnited States Tax Court · 1961