Lowell Wool By-Products Co. v. War Contracts Price Adjustment Board
United States Tax Court
The petitioner is a limited partnership, with two general partners with power of control over the business, and five limited partners with power to dissolve the partnership at any time.
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The petitioner is a limited partnership, with two general partners with power of control over the business, and five limited partners with power to dissolve the partnership at any time. During the fiscal year ending December 31, 1943, the petitioner had renegotiable sales of less than $ 500,000, but four of its limited partners were members, as wives, mother, and son-in-law, of three families which comprised the controlling ownership and directorship of Nichols, a corporation which had renegotiable sales exceeding $ 500,000, and the fifth limited partner was the wife of the…
1Opinion of the Court
OPINION.
Disney, Judge-.
Since we have found that the petitioner’s gross sales, after discounts of $620.15 for the fiscal year, are $97,769.92, it is apparent therefore that its renegotiable profits are no more than that amount, therefore are less than $500,000, and that the petitioner is, within the language of section 403 (c) (6) of the Renegotiation Act, exempt from renegotiation, unless, under the same section, as the respondent contends, it was “under the control of or controlling or under common control with” Nichols, the renegotiate sales of which were more than $500,000. We, therefore,…
2Cases cited4 opinions
- Mecom v. Fitzsimmons Drilling Co.Supreme Court of the United States · 1931
- Atlantic City Electric Co. v. CommissionerSupreme Court of the United States · 1933
- Moening v. War Contracts Price Adjustment BoardUnited States Tax Court · 1950
- Hug Co. v. War Contracts Price Adjustment BoardUnited States Tax Court · 1950
3Cited by1 opinion
- Lowell Wool By-Products Co. v. War Contracts Price Adjustment BoardUnited States Tax Court · 1950