W. Tip Davis Co. v. Patterson
United States Tax Court
1. Renegotiation -- Sales to Post Exchanges, Etc. -- Sales to post exchanges, ship service stores, officers' clubs, company funds and the like are not subject to renegotiation, since they do not involve funds appropriated by Congress. 2. Id. -- Purchase Orders. -- Direct sales to Army and Navy on purchase orders are subject to renegotiation, since purchase orders are contracts. 3. Id. -- Allocation of Costs and Expenses. -- Costs and expenses allocated between renegotiable…
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1. Renegotiation -- Sales to Post Exchanges, Etc. -- Sales to post exchanges, ship service stores, officers' clubs, company funds and the like are not subject to renegotiation, since they do not involve funds appropriated by Congress. 2. Id. -- Purchase Orders. -- Direct sales to Army and Navy on purchase orders are subject to renegotiation, since purchase orders are contracts. 3. Id. -- Allocation of Costs and Expenses. -- Costs and expenses allocated between renegotiable and nonrenegotiable sales on basis of sales where petitioner had used no accurate method of allocation. 4. Id. --…
1Opinion of the Court
OPINION.
MuRdock, Judge-.
The first point for decision under issue (1) is whether sales made by the petitioner during the period here in question to Army post exchanges, officers’ clubs, Navy ship service stores, and numerous armed forces organizations were subject to renegotiation. The evidence on this point is extremely limited. It shows that sales in the total amount of $4,326.61 were made to Army post exchanges, ship service stores and various military organizations and clubs, and' were paid for after April 28, 1942. The parties, in discussing this point, make no distinction between the…
2Cases cited3 opinions
- Standard Oil Co. of Cal. v. JohnsonSupreme Court of the United States · 1942
- Nat'l Elec. Welding Machs. Co. v. StimsonUnited States Tax Court · 1948
- Albert & J. M. Anderson Mfg. Co. v. Secretary of WarUnited States Tax Court · 1949
3Cited by10 opinions
- French v. War Contracts Price Adjustment BoardUnited States Tax Court · 1949
- Larrabee v. StimsonUnited States Tax Court · 1951
- Park Sherman Co. v. United StatesUnited States Tax Court · 1957
- Bibb Manufacturing Co. v. Secretary of WarUnited States Tax Court · 1949
- Bibb Mfg. Co. v. Secretary of WarUnited States Tax Court · 1949
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