Legal Opinion

Bell Aircraft Corp. v. Commissioner

United States Tax Court

Decided May 14, 1959No. Docket No. 68395Published

During the years 1942 through 1945 the petitioner allocated experimental, development, and production tooling costs to airplanes produced under four cost-plus-fixed-fee contracts with the United States. Due to a contract dispute, the United States refused to reimburse the petitioner for these costs, and the petitioner brought suit in the Court of Claims.

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During the years 1942 through 1945 the petitioner allocated experimental, development, and production tooling costs to airplanes produced under four cost-plus-fixed-fee contracts with the United States. Due to a contract dispute, the United States refused to reimburse the petitioner for these costs, and the petitioner brought suit in the Court of Claims. In 1951 the Court of Claims held in favor of the petitioner and this judgment was affirmed in 1952 by the Supreme Court of the United States. Held, that the judgment, which respondent concedes was abnormal income under section 456(a) of the…

1Opinion of the Court

Bell Aircraft Corporation, Petitioner, v. Commissioner of Internal Revenue, Respondent

Bell Aircraft Corp. v. Commissioner

Docket No. 68395

United States Tax Court

32 T.C. 355; 1959 U.S. Tax Ct. LEXIS 170;

May 14, 1959, Filed

Decision will be entered under Rule 50.

During the years 1942 through 1945 the petitioner allocated experimental, development, and production tooling costs to airplanes produced under four cost-plus-fixed-fee contracts with the United States. Due to a contract dispute, the United States refused to reimburse the petitioner for these costs, and the petitioner brought suit in the…

2Cases cited9 opinions

  1. Geyer, Cornell & Newell, Inc. v. CommissionerUnited States Tax Court · 1946
  2. A B C Brewing Corp. v. CommissionerUnited States Tax Court · 1953
  3. E. T. Slider, Inc. v. CommissionerUnited States Tax Court · 1945
  4. American Enka Corp. v. CommissionerUnited States Tax Court · 1958
  5. Bell Aircraft Corp. v. United StatesUnited States Court of Claims · 1951

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