Legal Opinion

Western Cartridge Co. v. Commissioner

United States Tax Court

Decided September 13, 1948No. Docket No. 9670Published

1. In 1940 and 1941 taxpayer entered into three contracts with the United States. Under the terms of the 1940 contract the Government, upon request of taxpayer, was to make advance payments not to exceed 30 per cent of cost of procurement and installation of manufacturing facilities. Under the two 1941 contracts the Government was to make advance payments of 30 per cent of the purchase or contract price of certain products manufactured by taxpayer.

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1. In 1940 and 1941 taxpayer entered into three contracts with the United States. Under the terms of the 1940 contract the Government, upon request of taxpayer, was to make advance payments not to exceed 30 per cent of cost of procurement and installation of manufacturing facilities. Under the two 1941 contracts the Government was to make advance payments of 30 per cent of the purchase or contract price of certain products manufactured by taxpayer. Taxpayer, at its request, reimbursed the Government by check for a portion of the advance payments under the 1940 contract in lieu of crediting…

1Opinion of the Court

Western Cartridge Company (Now: Olin Industries, Inc.), Petitioner, v. Commissioner of Internal Revenue, Respondent

Western Cartridge Co. v. Commissioner

Docket No. 9670

United States Tax Court

11 T.C. 246; 1948 U.S. Tax Ct. LEXIS 94;

September 13, 1948, Promulgated

Decision will be entered under Rule 50.

1. In 1940 and 1941 taxpayer entered into three contracts with the United States. Under the terms of the 1940 contract the Government, upon request of taxpayer, was to make advance payments not to exceed 30 per cent of cost of procurement and installation of manufacturing facilities. Under the two…

2Cases cited5 opinions

  1. Dixie Pine Products Co. v. CommissionerSupreme Court of the United States · 1944
  2. West Constr. Co. v. CommissionerUnited States Tax Court · 1946
  3. Gibson Products Co. v. CommissionerUnited States Tax Court · 1947
  4. Gould & Eberhardt, Inc. v. CommissionerUnited States Tax Court · 1947
  5. Western Cartridge Co. v. CommissionerUnited States Tax Court · 1948

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