Legal Opinion

Ellis Coat Co. v. Secretary of War

United States Tax Court

Decided November 28, 1947No. Docket No. 276-RPublished

The petitioner and corporation A, both principally owned by the same family, manufactured and sold women's coats and suits under an unwritten agreement whereby petitioner supplied the materials, designing, managerial services, and marketing, and corporation A manufactured the garments according to petitioner's orders.

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The petitioner and corporation A, both principally owned by the same family, manufactured and sold women's coats and suits under an unwritten agreement whereby petitioner supplied the materials, designing, managerial services, and marketing, and corporation A manufactured the garments according to petitioner's orders. Petitioner performed renegotiable contracts for coats, jungle hammocks, etc., which were manufactured by corporation A under the existing arrangement, petitioner's officers and executives supplying managerial services. Corporation A also performed a renegotiable contract for…

1Opinion of the Court

Ellis Coat Company, Inc., Petitioner, v. the Secretary of War, Respondent

Ellis Coat Co. v. Secretary of War

Docket No. 276-R.

United States Tax Court

9 T.C. 1004; 1947 U.S. Tax Ct. LEXIS 22;

November 28, 1947, Promulgated

The petitioner and corporation A, both principally owned by the same family, manufactured and sold women's coats and suits under an unwritten agreement whereby petitioner supplied the materials, designing, managerial services, and marketing, and corporation A manufactured the garments according to petitioner's orders. Petitioner performed renegotiable contracts for coats, jungle…

Also in this document: Dissent.

2Cases cited1 opinion

  1. Ellis Coat Co. v. Secretary of WarUnited States Tax Court · 1947

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