Nat Harrison Assoc., Inc. v. Commissioner
United States Tax Court
1. A domestic partnership entered into three contracts for construction of facilities used at missile-tracking stations in the Caribbean. It assigned the job of performing the work at the jobsites to a Panamanian corporation owned by the parties. The partnership subsequently transferred all of its assets and current business, except one contract, to a domestic corporation.
Read the full summary
1. A domestic partnership entered into three contracts for construction of facilities used at missile-tracking stations in the Caribbean. It assigned the job of performing the work at the jobsites to a Panamanian corporation owned by the parties. The partnership subsequently transferred all of its assets and current business, except one contract, to a domestic corporation. The Panamanian corporation performed the major part of the work under the contract, but the partnership remained liable as the prime contractor under the contracts and the partnership, and subsequently the domestic…
1Opinion of the Court
DpjsNNEN, Judge:
In these consolidated proceedings respondent determined the following deficiencies in income tax:
[[Image here]]
The issues for decision are:
Whether the net income from three contracts for construction of missile-tracking stations in the Caribbean was the income of, or can be allocated to, Nat G. Harrison, Jr. and Associates, an American partnership comprised of Nat G. Harrison, Jr., Jan E. Smith, and Alto Adams, and/or Nat Harrison Associates, Inc., an American corporation, organized to take over the partnership business, or was the income of Nat G. Harrison Overseas Corp., a…
2Cases cited41 opinions
- Lucas v. EarlSupreme Court of the United States · 1930
- Helvering v. HorstSupreme Court of the United States · 1940
- Helvering v. TaylorSupreme Court of the United States · 1935
- Moline Properties, Inc. v. CommissionerSupreme Court of the United States · 1943
- Harrison v. SchaffnerSupreme Court of the United States · 1941
36 more not listed; retrieve them via the Exa API.
3Cited by155 opinions
- Zmuda v. CommissionerUnited States Tax Court · 1982
- Estate of Horvath v. CommissionerUnited States Tax Court · 1973
- Southern Pacific Transp. Co. v. CommissionerUnited States Tax Court · 1980
- Foster v. Comm'rUnited States Tax Court · 1983
- Estate of Beck v. Comm'rUnited States Tax Court · 1971
150 more not listed; retrieve them via the Exa API.