McDonnell Aircraft Corp. v. Commissioner
United States Tax Court
1. Petitioner entered into a financing agreement with nine lending institutions to acquire funds necessary for financing its performance under war contracts with the War and Navy Departments, and under subcontracts with other prime contractors. This arrangement was made in accordance with Regulation "V" of Federal Reserve System, and was of the type commonly referred to during World War II, as a "V-Loan."
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1. Petitioner entered into a financing agreement with nine lending institutions to acquire funds necessary for financing its performance under war contracts with the War and Navy Departments, and under subcontracts with other prime contractors. This arrangement was made in accordance with Regulation "V" of Federal Reserve System, and was of the type commonly referred to during World War II, as a "V-Loan." Petitioner's borrowings pursuant to this arrangement were evidenced by its notes, and the Government acted as guarantor for 90 per cent of the indebtedness evidenced thereby. Held: The…
1Opinion of the Court
OPINION...Van Fossan, Judge:
During the years involved herein petitioner •was engaged in the manufacture and experimental development of aircraft and aircraft parts either under prime contracts with the War and Navy Departments or under subcontracts with other prime contractors. It was relatively a new corporation having been in existence only since July 6,1939. Its capital was limited and in order to carry out its commitments additional funds were needed. Prior to the early part of 1943 the required funds were made available in the form of advance payments from the Government. At the…
2Cases cited2 opinions
- Mahoney Motor Co. v. CommissionerUnited States Tax Court · 1950
- Brann & Stuart Co. v. CommissionerUnited States Tax Court · 1947
3Cited by14 opinions
- Singer Co. v. United StatesUnited States Court of Claims · 1971
- Weinstein v. CommissionerUnited States Tax Court · 1957
- Marquis v. CommissionerUnited States Tax Court · 1968
- T. J. Moss Tie Co. v. CommissionerUnited States Tax Court · 1952
- Cramp Shipbuilding Co. v. CommissionerUnited States Tax Court · 1951
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