Edell v. United States

OPINION.

Harron, Judge:

The first issue presents the problem whether any of the Edell partnership’s earnings for each of the 3 years, 1943-1945, inclusive, is subject to renegotiation under the provisions of section 403 (a) (5) (B) of the Renegotiation Act of .1942, as amended.2 If that issue is decided in the affirmative, another question must be decided, the amount in each year of the partnership’s excessive profits, if any, under the provisions of section 403 (a) (4) (A). It is now well established that in a Tax Court proceeding for the redetermination of excessive profits the petitioner has…