Legal Opinion

Connecticut Marine Boiler Works v. Secretary Maritime Com.

United States Tax Court

Decided February 15, 1951No. Docket No. 447-RPublishedCited by 5 opinions

1. Held, that renegotiation of petitioner's war contracts completed during its fiscal year ended December 31, 1942, was commenced within one year thereafter within the meaning of section 403 (c) (6) of the Renegotiation Act of 1942. 2. Held, that the portion of petitioner's gross sales for 1942 which was received from subcontracts not completed until 1943 was part of petitioner's renegotiable business for 1942. 3. Reasonable compensation for petitioner's two officers in 1942…

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1. Held, that renegotiation of petitioner's war contracts completed during its fiscal year ended December 31, 1942, was commenced within one year thereafter within the meaning of section 403 (c) (6) of the Renegotiation Act of 1942. 2. Held, that the portion of petitioner's gross sales for 1942 which was received from subcontracts not completed until 1943 was part of petitioner's renegotiable business for 1942. 3. Reasonable compensation for petitioner's two officers in 1942 determined. 4. The amount of excessive profits realized by petitioner in 1942 determined.

1Opinion of the Court

OPINION.

TTtt.t.j Judge:

The first question for our determination is whether respondent commenced renegotiation of those war contracts of petitioner completed during petitioners fiscal year ended December 31, 1942, within one year from that date in accordance with the provisions of section 403 (c) (6) of the Renegotiation Act of 1942.1 It is respondent’s contention that renegotiation commenced with the conference held between the representatives of petitioner and respondent on December 14, 1943, and therefore it complied with section 403 (c) (6). On the other hand, petitioner asserts that…

2Cases cited5 opinions

  1. Stein Bros. Mfg. Co. v. Secretary of WarUnited States Tax Court · 1946
  2. J. H. Sessions & Son v. Secretary of WarUnited States Tax Court · 1946
  3. Spray Cotton Mills v. Secretary of WarUnited States Tax Court · 1947
  4. Whitman v. CommissionerUnited States Tax Court · 1949
  5. Bibb Manufacturing Co. v. Secretary of WarUnited States Tax Court · 1949

3Cited by5 opinions

  1. Waltham Screw Co. v. Renegotiation BoardUnited States Tax Court · 1958
  2. Connecticut Marine Boiler Works v. Secretary Maritime Com.United States Tax Court · 1951
  3. Cooke v. CommissionerUnited States Tax Court · 1951
  4. Harolds Club v. CommissionerUnited States Tax Court · 1963
  5. Waltham Screw Co. v. Renegotiation BoardUnited States Tax Court · 1958

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