Armstrong v. War Contracts Price Adjustment Board
United States Tax Court
Petitioner, a manufacturers' representative, during 1943 and 1944 earned commissions based upon orders largely from commercial firms to which he had been selling for his principals for many years. The products sold by him for his principals had in large measure a war end use by the vendees in contracting with the Government.
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Petitioner, a manufacturers' representative, during 1943 and 1944 earned commissions based upon orders largely from commercial firms to which he had been selling for his principals for many years. The products sold by him for his principals had in large measure a war end use by the vendees in contracting with the Government. Held, that to the extent of such war end use of products sold, the petitioner was a subcontractor within section 403 (a) (5) (B) of the Renegotiation Act of 1943. Amount of excessive profits determined. Held, further, that the fact that petitioner declined to file the…
1Opinion of the Court
OPINION.
Disney, Judge:
Briefly stated, the questions presented are whether the petitioner is a subcontractor, whether his earnings were excessive, and as to the year 1944 whether the proceedings were instituted within the time prescribed by law.
Since the last question, as to limitation, determines whether we consider that year on its merits, we will first give attention to it. The petitioner’s view, in substance, is that since on April 10, 1945, he declined to furnish the reports required by the respondent and again declined so to do on November 9,1945, both times upon the ground that he was…
2Cases cited3 opinions
- Grob Bros. v. Secretary of WarUnited States Tax Court · 1947
- Nat'l Elec. Welding Machs. Co. v. StimsonUnited States Tax Court · 1948
- Providence Wool Combing Co. v. Secretary of WarUnited States Tax Court · 1950
3Cited by8 opinions
- A. C. Ball Co. v. United StatesUnited States Court of Claims · 1976
- Armstrong v. War Contracts Price Adjustment BoardCourt of Appeals for the D.C. Circuit · 1952
- Edell v. United StatesUnited States Tax Court · 1957
- Bittner v. United StatesUnited States Tax Court · 1956
- Armstrong v. War Contracts Price Adjustment BoardUnited States Tax Court · 1950
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