Legal Opinion

Bittner v. United States

United States Tax Court

Decided June 29, 1956No. Docket No. 354-RPublishedCited by 1 opinion

Held, on the facts, that a contract under which petitioner received payments during the calendar year 1943 was a subcontract within the meaning of section 403 (a) (5) (B) of the Renegotiation Act of 1943.

1Opinion of the Court

OPINION.

TuRNee, Judge:

By section 403 (c) (6) of the Eenegotiation Act of 1943,2 the profits received under a subcontract, as defined by section 403 (a) (5) (B) of the Act, are not subject to renegotiation, unless the aggregate of the amounts received or accrued in a fiscal year ending after June 30,1943, exceeds $25,000. The income of the petitioner for the calendar year 1943 under the contract herein was in excess of $25,000, and petitioner has stipulated that if the $25,000 limitation specified in section 403 (c) (6) is the controlling limitation, a decision may be entered “determining…

2Cases cited2 opinions

  1. Iverson & Laux, Inc. v. ForrestalUnited States Tax Court · 1946
  2. Armstrong v. War Contracts Price Adjustment BoardUnited States Tax Court · 1950

3Cited by1 opinion

  1. Bittner v. United StatesUnited States Tax Court · 1956

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