Cramp Shipbuilding Co. v. Commissioner
United States Tax Court
1. Government Contracts -- Year of Accrual and Amount of Accrual under Cost-Plus-Fixed-Fee Contracts. -- Where under cost-plus-fixed-fee contracts there is a dispute between the contracting parties as to the amount of reimbursable costs and fees, held, that the taxpayer should accrue as income the amounts of such items in the year in which the Government agrees that it is entitled to reimbursement of costs and payment of fees; held, further, that where the Government…
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1. Government Contracts -- Year of Accrual and Amount of Accrual under Cost-Plus-Fixed-Fee Contracts. -- Where under cost-plus-fixed-fee contracts there is a dispute between the contracting parties as to the amount of reimbursable costs and fees, held, that the taxpayer should accrue as income the amounts of such items in the year in which the Government agrees that it is entitled to reimbursement of costs and payment of fees; held, further, that where the Government subsequently recoups part of such items, section 3806 (a) (2) of the Internal Revenue Code requires that the amount of costs…
1Opinion of the Court
OPINION.
Aeundell, Jvdge:
The issues that remain for decision may be classified under two headings. Under the first heading, there is a group of issues that arise out of the respondent’s determinations of deficiencies and which are based on the petitioner’s allegations of error in such determinations. These issues have to do principally with the proper year in which fees and reimbursable costs under contracts with the United States Navy are properly includible in income. As to these, the facts have been stipulated and are herein referred to as the stipulated issues.
Under the second heading,…
2Cases cited12 opinions
- North American Oil Consolidated v. BurnetSupreme Court of the United States · 1932
- Burnet v. Sanford & Brooks Co.Supreme Court of the United States · 1931
- Spring City Foundry Co. v. CommissionerSupreme Court of the United States · 1934
- Security Flour Mills Co. v. CommissionerSupreme Court of the United States · 1944
- Burnet v. LoganSupreme Court of the United States · 1931
7 more not listed; retrieve them via the Exa API.
3Cited by11 opinions
- Mid-State Products Co. v. CommissionerUnited States Tax Court · 1954
- Riss & Co. v. CommissionerUnited States Tax Court · 1964
- Commissioner v. Harriman Ripley & Co.Court of Appeals for the Third Circuit · 1953
- Commissioner of Internal Revenue v. Harriman Ripley & Co., Incorporated, Successor by Merger to Cramp Shipbuilding CompanyCourt of Appeals for the Third Circuit · 1953
- Miller v. CommissionerUnited States Tax Court · 1953
6 more not listed; retrieve them via the Exa API.