Hoffman v. United States
United States Tax Court
Petitioners were engaged in the manufacture and repair of machinery used in the processing of quartz. P. Reynold Hoffman and his sister, Bertha S. Hoffman, were the sole and equal partners in such business. P. Reynold Hoffman supervised and controlled the production phase of this business while Bertha S. Hoffman supervised the office work and the routine operation of the business.
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Petitioners were engaged in the manufacture and repair of machinery used in the processing of quartz. P. Reynold Hoffman and his sister, Bertha S. Hoffman, were the sole and equal partners in such business. P. Reynold Hoffman supervised and controlled the production phase of this business while Bertha S. Hoffman supervised the office work and the routine operation of the business. The partnership agreement stated that "P. Reynold Hoffman shall make all partnership contracts and shall have the management of the partnership affairs." P. Reynold Hoffman also owned the majority of the outstanding…
1Opinion of the Court
OPINION.
Rice, Judge:
Petitioner’s sales during each of the years here in issue were less than the jurisdictional minimum of $500,000 required by section 403 (c) (6) of the Renegotiation Act of 19431 before excessive profits can be renegotiated. The sole issue before us is whether petitioner was under the control of, or under common control with, the P. R. Hoffman Company, thus permitting their combined sales to be. used to bring petitioner within the provisions of the Act.
The respondent’s principal contention is that petitioner and the Corporation were both under the actual control2 of…
2Cases cited3 opinions
- Lowell Wool By-Products Co. v. War Contracts Price Adjustment BoardCourt of Appeals for the D.C. Circuit · 1951
- Warner v. War Contracts Price Adjustment BoardUnited States Tax Court · 1950
- Moening v. War Contracts Price Adjustment BoardUnited States Tax Court · 1950
3Cited by10 opinions
- Shultz v. Mack Farland & Sons Roofing Co.Court of Appeals for the Fifth Circuit · 1969
- Shultz v. Mack Farland & Sons Roofing Co.Court of Appeals for the Fifth Circuit · 1969
- Finnie Co. v. United StatesUnited States Tax Court · 1959
- Haas v. United StatesUnited States Tax Court · 1955
- Zarkin v. United StatesUnited States Tax Court · 1958
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