Legal Opinion

Rockwell International Corp. v. Commissioner

United States Tax Court

Decided October 13, 1981No. Docket No. 3121-77PublishedCited by 24 opinions

In 1966, petitioner's predecessor in interest entered into a fixed-price incentive-type subcontract (P.O. 181) with General Dynamics Corp., which had contracted with the U.S. Air Force to oversee the development of the F-111 aircraft. P.O. 181 required petitioner to develop and manufacture components for the avionics systems of these aircraft. Under the contract, petitioner was to receive progress payments equal to a certain percentage of its incurred costs.

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In 1966, petitioner's predecessor in interest entered into a fixed-price incentive-type subcontract (P.O. 181) with General Dynamics Corp., which had contracted with the U.S. Air Force to oversee the development of the F-111 aircraft. P.O. 181 required petitioner to develop and manufacture components for the avionics systems of these aircraft. Under the contract, petitioner was to receive progress payments equal to a certain percentage of its incurred costs. The contract also provided that title to all materials acquired or manufactured under the contract was at all times vested in the…

1Opinion of the Court

Dawson, Judge:

Respondent determined a deficiency in petitioner’s Federal income tax for the taxable year ended September 30, 1969, in the amount of $8,580,000. The basic question presented for decision is whether petitioner’s predecessor in interest, North American Rockwell Corp., improperly claimed a lower of cost or market inventory writedown during the year in issue in the amount of $16,250,000 with respect to costs accumulated under a partially completed defense subcontract.1

FINDINGS OF FACT

Some of the facts have been stipulated and are found accordingly. The stipulation and the attached…

2Cases cited32 opinions

  1. United States v. AndersonSupreme Court of the United States · 1926
  2. Automobile Club of Mich. v. CommissionerSupreme Court of the United States · 1957
  3. Lucas v. American Code Co.Supreme Court of the United States · 1930
  4. Ithaca Trust Co. v. United StatesSupreme Court of the United States · 1929
  5. Thor Power Tool Co. v. CommissionerSupreme Court of the United States · 1979

27 more not listed; retrieve them via the Exa API.

3Cited by24 opinions

  1. Peninsula Steel Products & Equipment Co. v. CommissionerUnited States Tax Court · 1982
  2. Hamilton Industries, Inc. v. CommissionerUnited States Tax Court · 1991
  3. Rockwell International Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1982
  4. Ron Lykins, Inc. v. Comm'rUnited States Tax Court · 2009
  5. Wal-Mart Stores, Inc. & Subsidiaries v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1998

19 more not listed; retrieve them via the Exa API.

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