Bell Aircraft Corp. v. Commissioner
United States Tax Court
During the years 1942 through 1945 the petitioner allocated experimental, development, and production tooling costs to airplanes produced under four cost-plus-fixed-fee contracts with the United States. Due to a contract dispute, the United States refused to reimburse the petitioner for these costs, and the petitioner brought suit in the Court of Claims.
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During the years 1942 through 1945 the petitioner allocated experimental, development, and production tooling costs to airplanes produced under four cost-plus-fixed-fee contracts with the United States. Due to a contract dispute, the United States refused to reimburse the petitioner for these costs, and the petitioner brought suit in the Court of Claims. In 1951 the Court of Claims held in favor of the petitioner and this judgment was affirmed in 1952 by the Supreme Court of the United States. Held, that the judgment, which respondent concedes was abnormal income under section 456(a) of the…
1Opinion of the Court
Mulronet, Judge:
Respondent determined deficiencies hi the petitioner’s income and excess profits taxes for the year 1952 in the amount of $946,467.11.
The issue before us is whether, under section 456 of the Internal Revenue Code of 1939,1 the petitioner is entitled, in computing its excess profits tax for 1952, to exclude from its gross income the income arising from a judgment to the extent that such income is attributable to years prior to 1950.
FINDINGS OF FACT.
The stipulated facts are herein incorporated by this reference.
Bell Aircraft Corporation, the petitioner, is a corporation…
2Cases cited8 opinions
- Geyer, Cornell & Newell, Inc. v. CommissionerUnited States Tax Court · 1946
- A B C Brewing Corp. v. CommissionerUnited States Tax Court · 1953
- E. T. Slider, Inc. v. CommissionerUnited States Tax Court · 1945
- American Enka Corp. v. CommissionerUnited States Tax Court · 1958
- Bell Aircraft Corp. v. United StatesUnited States Court of Claims · 1951
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3Cited by3 opinions
- Continental Can Company, Inc. v. The United StatesUnited States Court of Claims · 1970
- Bell Aircraft Corp. v. CommissionerUnited States Tax Court · 1959
- Continental Can Company, Inc. v. The United StatesUnited States Court of Claims · 1970