Ofria v. Commissioner
United States Tax Court
Ts are shareholders of Contract Machining Corp. (CMC), an electing small business corporation. CMC produced a fuze bomb coupler for the Air Force under several defense procurement contracts.
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Ts are shareholders of Contract Machining Corp. (CMC), an electing small business corporation. CMC produced a fuze bomb coupler for the Air Force under several defense procurement contracts. Each of these contracts contained a "value engineering incentive" clause under which a contractor could submit proposals for modifying the contract specifications, thereby producing cost savings for the Air Force; the acceptance of such proposals would entitle the contractor to share in the cost savings. Pursuant to the value engineering incentive clause, CMC submitted four value engineering proposals to…
1Opinion of the Court
Carmelo V. Ofria and Marjorie P. Ofria, et al., 1 Petitioners v. Commissioner of Internal Revenue, Respondent
Ofria v. Commissioner
Docket Nos. 12304-77, 12305-77, 12306-77, 4671-78
United States Tax Court
77 T.C. 524; 1981 U.S. Tax Ct. LEXIS 67; 29 Cont. Cas. Fed. (CCH) P81,854;
August 31, 1981, Filed
Decisions will be entered under Rule 155.
Ts are shareholders of Contract Machining Corp. (CMC), an electing small business corporation. CMC produced a fuze bomb coupler for the Air Force under several defense procurement contracts. Each of these contracts contained a "value engineering incentive"…
2Cases cited32 opinions
- Commissioner v. Gillette Motor Transport, Inc.Supreme Court of the United States · 1960
- Myers v. Comm'rUnited States Tax Court · 1946
- Jet Spray Cooler, Inc. v. CramptonMassachusetts Supreme Judicial Court · 1972
- PPG Indus., Inc. v. CommissionerUnited States Tax Court · 1970
- E. I. Du Pont De Nemours and Company v. United StatesUnited States Court of Claims · 1961
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