Legal Opinion

Waltham Screw Co. v. Renegotiation Board

United States Tax Court

Decided October 27, 1958No. Docket No. 918-RPublishedCited by 4 opinions

Petitioner ascertained the amount of its renegotiable subcontract sales by inquiry of its customers. After the petition was filed, the Board by amended answer sought an increase in the amount of excessive profits. It was stipulated that the Board's analysis of petitioner's records showed additional orders indicating renegotiable subcontracts. The analysis was not put in evidence and petitioner says it was prepared to show that such orders were not renegotiable.

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Petitioner ascertained the amount of its renegotiable subcontract sales by inquiry of its customers. After the petition was filed, the Board by amended answer sought an increase in the amount of excessive profits. It was stipulated that the Board's analysis of petitioner's records showed additional orders indicating renegotiable subcontracts. The analysis was not put in evidence and petitioner says it was prepared to show that such orders were not renegotiable. Held: 1. The Board failed to meet its burden of proving excessive profits in an amount greater than that originally determined. 2.…

1Opinion of the Court

Tietjens, Judge:

The Renegotiation Board determined that Wal-tham Screw Company had realized excessive profits of $37,951 in 1951 from contracts and subcontracts subject to renegotiation. Wal-tham Screw Company filed a petition pursuant to the Renegotiation Act of 1951, 65 Stat. 7 (Pub. L. No. 9, 82d Cong., 1st Sess.). By amended answer the Board alleges that the petitioner realized excessive profits in the amount of $50,000. The petitioner contends that it had no excessive profits in 1951. Issues for decision relate to the amount of subcontracts subject to renegotiation, the reasonableness of…

2Cases cited5 opinions

  1. Cohen v. Secretary of WarUnited States Tax Court · 1946
  2. Albert & J. M. Anderson Mfg. Co. v. Secretary of WarUnited States Tax Court · 1949
  3. Connecticut Marine Boiler Works v. Secretary Maritime Com.United States Tax Court · 1951
  4. Eastern Machinery Co. v. Under Secretary of WarUnited States Tax Court · 1949
  5. Quartz Laboratories, Inc. v. Secretary of WarUnited States Tax Court · 1948

3Cited by4 opinions

  1. Beets v. Renegotiation BoardUnited States Tax Court · 1962
  2. Beets v. Renegotiation BoardUnited States Tax Court · 1962
  3. Beets v. Renegotiation BoardUnited States Tax Court · 1962
  4. Waltham Screw Co. v. Renegotiation BoardUnited States Tax Court · 1958

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