J. H. Sessions & Son v. Secretary of War
United States Tax Court
1. Renegotiation -- Statute of Limitations. -- The period of limitation provided in section 403 (c) (6) of the 1942 amendment applies in the case of "overall" or fiscal year renegotiation. 2. Id. -- "Commence," as Used Therein. -- A letter requesting estimates of the gross amounts of contracts solely for the purpose of assignment of the petitioner to a renegotiating agency did not commence the renegotiation within the meaning of that word as used in section 403 (c) (6).
1Opinion of the Court
OPINION.
Murdock, Judge-.
The Secretary of War made a unilateral determination that .$90,000 of the profits realized by the petitioner during its fiscal year ended December 31, 1942, under contracts and subcontracts subject to renegotiation pursuant to the provisions of the Renegotiation Act were excessive. The statutory notice of this determination dated March 27, 1945, was mailed to and received by the petitioner. The present proceeding is brought to contest that determination. The petitioner has assigned two errors, but argues only one, and will be deemed to have abandoned the other. He…
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