Legal Opinion

Ofria v. Commissioner

United States Tax Court

Decided August 31, 1981No. Docket Nos. 12304-77, 12305-77, 12306-77, 4671-78PublishedCited by 9 opinions

Ts are shareholders of Contract Machining Corp. (CMC), an electing small business corporation. CMC produced a fuze bomb coupler for the Air Force under several defense procurement contracts.

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Ts are shareholders of Contract Machining Corp. (CMC), an electing small business corporation. CMC produced a fuze bomb coupler for the Air Force under several defense procurement contracts. Each of these contracts contained a "value engineering incentive" clause under which a contractor could submit proposals for modifying the contract specifications, thereby producing cost savings for the Air Force; the acceptance of such proposals would entitle the contractor to share in the cost savings. Pursuant to the value engineering incentive clause, CMC submitted four value engineering proposals to…

1Opinion of the Court

Raum, Judge:

The Commissioner determined the following deficiencies with respect to petitioners’ 1972, 1973, and 1974 income taxes:

Docket No. Petitioner Year Deficiency

12304-77 Carmelo V. and

Marjorie P. Ofria. 1972 $18,074.05

4671-78 do. 1973 47,567.43

1974 27,355.28

12305-77 James M. and Grace

C. Ofria. 1972 22,182.47

1973 43,760.36

1974 29,556.18

12306-77 Constance Ofria2 . 1972 18,168.03

1973 51,678.00

1974 30,532.25

The husband-petitioners and Constance Ofria are three of the four equal shareholders of Contract Machining Corp. (CMC), an electing small business corporation. At issue is whether…

2Cases cited31 opinions

  1. Commissioner v. Gillette Motor Transport, Inc.Supreme Court of the United States · 1960
  2. Myers v. Comm'rUnited States Tax Court · 1946
  3. Jet Spray Cooler, Inc. v. CramptonMassachusetts Supreme Judicial Court · 1972
  4. PPG Indus., Inc. v. CommissionerUnited States Tax Court · 1970
  5. E. I. Du Pont De Nemours and Company v. United StatesUnited States Court of Claims · 1961

26 more not listed; retrieve them via the Exa API.

3Cited by9 opinions

  1. Freda v. COMMISSIONER OF INTERNAL REVENUECourt of Appeals for the Seventh Circuit · 2011
  2. Lockheed Martin Corp. v. United StatesUnited States Court of Federal Claims · 1998
  3. Bachmann v. Comm'rUnited States Tax Court · 2009
  4. Freda v. COMMISSIONER OF INTERNAL REVENUECourt of Appeals for the Seventh Circuit · 2011
  5. Gilson v. CommissionerUnited States Tax Court · 1984

4 more not listed; retrieve them via the Exa API.

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