LTV Aerospace Corp. v. Renegotiation Board
United States Tax Court
Held: 1. Expenditures for research and development, which were made and properly capitalized in prior years and which were allocable to renegotiable business, were costs of renegotiable business in the year the project was abandoned and the expenditures were charged off against income. 2. Under the contractor's qualified profit-sharing plan, the contributions were to be computed and made on the basis of profits before reduction through renegotiation.
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Held: 1. Expenditures for research and development, which were made and properly capitalized in prior years and which were allocable to renegotiable business, were costs of renegotiable business in the year the project was abandoned and the expenditures were charged off against income. 2. Under the contractor's qualified profit-sharing plan, the contributions were to be computed and made on the basis of profits before reduction through renegotiation. Accordingly, such contributions were chargeable in full as costs of renegotiable business for years to which such contributions related. 3. It…
1Opinion of the Court
Simpson, Judge:
The respondent, by unilateral orders dated August 16, 1955, and April 23, 1957, determined that Temco Aircraft Corp. (Temco), the predecessor in interest of the petitioner LTV Aerospace Corp., realized excessive profits of $750,000 in 1952 and $3,500,000 in 1953. Under section 108 of the Renegotiation Act of 1951,1 the petitioner seeks de novo determinations of its excessive profits, if any. The petitions and answers thereto were timely filed. By amended answers, the respondent now claims excessive profits for 1952 in the amount of $2,800,000 and for 1953 in the amount of…
2Cases cited16 opinions
- Cohen v. Secretary of WarUnited States Tax Court · 1946
- Hart-Bartlett-Sturtevant Grain Co. v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1950
- Ring Constr. Corp. v. Secretary of WarUnited States Tax Court · 1947
- Ring Const. Corporation v. Secretary of War of United StatesCourt of Appeals for the D.C. Circuit · 1949
- Wooster Rubber Co. v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1951
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3Cited by5 opinions
- A. C. Ball Co. v. United StatesUnited States Court of Claims · 1976
- Aero Spacelines, Inc. v. United StatesUnited States Court of Claims · 1976
- Mason & Hanger-Silas Mason Co. v. United StatesUnited States Court of Claims · 1975
- Healey v. Meinen (In Re Meinen)United States Bankruptcy Court, W.D. Pennsylvania · 1998
- LTV Aerospace Corp. v. Renegotiation BoardUnited States Tax Court · 1968