Rockwell International Corp. v. Commissioner
United States Tax Court
In 1966, petitioner's predecessor in interest entered into a fixed-price incentive-type subcontract (P.O. 181) with General Dynamics Corp., which had contracted with the U.S. Air Force to oversee the development of the F-111 aircraft. P.O. 181 required petitioner to develop and manufacture components for the avionics systems of these aircraft. Under the contract, petitioner was to receive progress payments equal to a certain percentage of its incurred costs.
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In 1966, petitioner's predecessor in interest entered into a fixed-price incentive-type subcontract (P.O. 181) with General Dynamics Corp., which had contracted with the U.S. Air Force to oversee the development of the F-111 aircraft. P.O. 181 required petitioner to develop and manufacture components for the avionics systems of these aircraft. Under the contract, petitioner was to receive progress payments equal to a certain percentage of its incurred costs. The contract also provided that title to all materials acquired or manufactured under the contract was at all times vested in the…
1Opinion of the Court
Rockwell International Corporation, Petitioner v. Commissioner of Internal Revenue, Respondent
Rockwell International Corp. v. Commissioner
Docket No. 3121-77
United States Tax Court
77 T.C. 780; 1981 U.S. Tax Ct. LEXIS 45;
October 13, 1981, Filed
Decision will be entered for the respondent.
In 1966, petitioner's predecessor in interest entered into a fixed-price incentive-type subcontract (P.O. 181) with General Dynamics Corp., which had contracted with the U.S. Air Force to oversee the development of the F-111 aircraft. P.O. 181 required petitioner to develop and manufacture components for the…
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