Legal Opinion

Wolff & Phillips v. Macauley

United States Tax Court

Decided January 27, 1947No. Docket No. 498-RPublishedCited by 15 opinions

Petitioners are architects operating in partnership. In the calendar year 1942 they received payments under four subcontracts which called for the design and supervision of construction of numerous buildings at shipyards in Portland, Oregon, and Vancouver, Washington.

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Petitioners are architects operating in partnership. In the calendar year 1942 they received payments under four subcontracts which called for the design and supervision of construction of numerous buildings at shipyards in Portland, Oregon, and Vancouver, Washington. Under two of the subcontracts petitioners agreed, after preparing drawings for the buildings, "to issue invitations and proper drawings of the building being bid on to prospective bidders, together with copies of the standard form of subcontract and the Union contract of the Kaiser Company, Inc." Under the third subcontract,…

1Opinion of the Court

OPINION.

Arundell, Judge:

The respondent has moved that this proceeding be dismissed for lack of jurisdiction under section 403 (e) (2) of the Renegotiation Act, as amended.

On March 12, 1946, respondent determined that the amount of excessive profits of the petitioners fob the calendar year 1942 under their renegotiable contracts was $60,000, and notice of his determination was sent to the petitioners on that date. On June 7,1946, petitioners filed their petition for a redetermination by this Court, and on September 19, 1946, an amended petition, hereinafter referred to as the petition.

The…

2Cases cited1 opinion

  1. Iverson & Laux, Inc. v. ForrestalUnited States Tax Court · 1946

3Cited by15 opinions

  1. Dowell v. ForrestalUnited States Tax Court · 1949
  2. Edell v. United StatesUnited States Tax Court · 1957
  3. French v. War Contracts Price Adjustment BoardUnited States Tax Court · 1949
  4. Fine v. War Contracts Price Adjustment BoardUnited States Tax Court · 1947
  5. Wolff v. MacauleyUnited States Tax Court · 1949

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