Beck Chemical Equipment Corp. v. Commissioner
United States Tax Court
In January 1942, petitioner corporation entered into an oral agreement with Beattie Manufacturing Company for the manufacture and sale of flame throwers, a war device, to the United States Government under the terms of which petitioner agreed to and did make available to the common enterprise an invention (for which application for patent was pending) for fabricating such flame throwers, and also the engineering services of Beck, the inventor, its principal shareholder.
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In January 1942, petitioner corporation entered into an oral agreement with Beattie Manufacturing Company for the manufacture and sale of flame throwers, a war device, to the United States Government under the terms of which petitioner agreed to and did make available to the common enterprise an invention (for which application for patent was pending) for fabricating such flame throwers, and also the engineering services of Beck, the inventor, its principal shareholder. Beattie agreed to and did furnish all production facilities, financing, and sales functions to exploit the flame thrower.…
1Opinion of the Court
OPINION.
FisheR, Judge:
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Respondent determined that petitioner was a member of a joint venture, taxable as a partnership for Federal income tax purposes during the years 1944 and 1945, and, therefore, that its distributive share of the net profits thereof were taxable to petitioner in said years under sections 182 and 183 of the Internal Revenue Code of 1939. Petitioner contends that Beck and Beattie Manufacturing Company did not enter into a joint venture, and that regardless of whether such business relationship existed, petitioner had no taxable income for either year in issue since it did…
2Cases cited29 opinions
- Commissioner v. CulbertsonSupreme Court of the United States · 1949
- Commissioner v. TowerSupreme Court of the United States · 1946
- Commissioner v. Lane-Wells Co.Supreme Court of the United States · 1944
- Heiner v. MellonSupreme Court of the United States · 1938
- Place v. CommissionerUnited States Tax Court · 1951
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3Cited by114 opinions
- Perlmutter v. CommissionerUnited States Tax Court · 1965
- Paula Constr. Co. v. CommissionerUnited States Tax Court · 1972
- Luna v. CommissionerUnited States Tax Court · 1964
- Shomaker v. CommissionerUnited States Tax Court · 1962
- Heman v. CommissionerUnited States Tax Court · 1959
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