Manoogian Fund v. United States
United States Tax Court
The Tax Court having ruled that it has jurisdiction, held petitioner has failed to carry its burden of showing that its war contracts were not subject to renegotiation by reason of being an organization exempt from tax within the purview of section 101 (6), 1939 Code, as provided in section 403 (i) (1) (D) of the Renegotiation Act.
1Opinion of the Court
OPINION.
LeMiRE, Judge:
After various preliminary maneuvers these consolidated proceedings are here for a determination on the merits. They involve the redetermination of excessive profits of the petitioner for its fiscal period June 1, 1944, through December 31, 1944, and for the fiscal year ended December 31,1945.
The primary question presented relates to the jurisdiction of this Court under the Renegotiation Act of 1943 to determine the status of the petitioner within the purview of section 101 (6) of the Internal Revenue Code of 1939. If the answer is in the affirmative, the petitioner’s…
2Cases cited5 opinions
- Aircraft & Diesel Equipment Corp. v. HirschSupreme Court of the United States · 1947
- MacAuley v. Waterman Steamship Corp.Supreme Court of the United States · 1946
- Bank of Commerce v. Tennessee Ex Rel. MemphisSupreme Court of the United States · 1896
- Heiner v. Colonial Trust Co.Supreme Court of the United States · 1927
- Underwriters' Laboratories, Inc. v. CommissionerCourt of Appeals for the Seventh Circuit · 1943
3Cited by6 opinions
- A. C. Ball Co. v. United StatesUnited States Court of Claims · 1976
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- Lorain Ave. Clinic v. CommissionerUnited States Tax Court · 1958
- Marie and Alex Manoogian Fund, D/B/A Metal Parts Manufacturing Company v. United StatesCourt of Appeals for the Sixth Circuit · 1956
- Lorain Ave. Clinic v. CommissionerUnited States Tax Court · 1958
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