Legal Opinion

Haas v. United States

United States Tax Court

Decided February 18, 1955No. Docket Nos. 808-R, 809-RPublishedCited by 3 opinions

On May 1, 1944, H and W formed partnership #1 with A, the brother of H. H and W together owned 95 per cent of the partnership. The partnership was successful in manufacturing a product made possible by a production technique which H had developed. On January 28, 1945, H and W sold all their interest in the partnership to various individuals except 20 per cent which they retained.

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On May 1, 1944, H and W formed partnership #1 with A, the brother of H. H and W together owned 95 per cent of the partnership. The partnership was successful in manufacturing a product made possible by a production technique which H had developed. On January 28, 1945, H and W sold all their interest in the partnership to various individuals except 20 per cent which they retained. On February 1, 1945, by agreement between both the new and the old partners, partnership #1 was expressly dissolved and partnership #2 formed to continue the business under the same contracts and processes formerly…

1Opinion of the Court

OPINION.

Turner, Judge:

The principal issue for onr decision is whether either Haas Mold Company #1 or Haas Mold Company #2, or both of them, were under the control of or controlling or under common control with either Metal Parts Corporation or Haas Foundry Company within the meaning of section 403 (c) (6) of the Eenegotiation Act.2 However, for reasons of convenience, we dispose first of an argument put forth by the petitioners on brief. The petitioners contend that Haas Mold Company #1 and Haas Mold Company #2 were in fact one continuous partnership, with fiscal years beginning on May 1,1944…

2Cases cited3 opinions

  1. Hoffman v. United StatesUnited States Tax Court · 1954
  2. Pechtel v. United StatesUnited States Tax Court · 1952
  3. Glenfield Machine & Tool Co. v. War Contracts Price Adjustment BoardUnited States Tax Court · 1951

3Cited by3 opinions

  1. Zarkin v. United StatesUnited States Tax Court · 1958
  2. Haas v. United StatesUnited States Tax Court · 1955
  3. Zarkin v. United StatesUnited States Tax Court · 1958

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