Ellis Coat Co. v. Secretary of War
United States Tax Court
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
OPINION.
Hill, Judge:
We must determine first, how much profit petitioner made in 1943 on its renegotiable contracts and, secondly, what part of such profit, if any, is excessive. There are three questions affecting the determination of how much profit petitioner made: (1) The reasonableness of salaries paid by petitioner to its officers and executives, (2) what part of such salaries, if any, must be allocated to Independent, and (3) what part of certain general expenses including salaries must be allocated to renegotiable business.
In 1943 petitioner paid its officers and executives a total of…
2Cited by7 opinions
- Major Coat Co. v. United StatesUnited States Court of Claims · 1976
- Martin Mfg. Co. v. Renegotiation BoardUnited States Tax Court · 1965
- S. S. Silberblatt, Inc. v. Renegotiation BoardUnited States Tax Court · 1969
- Ellis Coat Co. v. Secretary of WarUnited States Tax Court · 1947
- Martin Mfg. Co. v. Renegotiation BoardUnited States Tax Court · 1965
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