Rosner v. War Contracts Price Adjustment Board
United States Tax Court
Petitioner, during the first 6 months of 1943, earned commission on orders when they were accepted by the contractor, the amount of which was payable to him not later than the year in which the articles were delivered.
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Petitioner, during the first 6 months of 1943, earned commission on orders when they were accepted by the contractor, the amount of which was payable to him not later than the year in which the articles were delivered. On July 1, 1943, when commission had been earned on orders but delivery had not been made, the parties amended the contract to provide for payment of the commission and commission on orders obtained thereafter by petitioner, after payment for delivered material and then in equal annual installments over a period of 10 years without security or interest. Amounts payable under…
1Opinion of the Court
OPINION.
Disney, Judge:
An issue preliminary to the question of excessive profits, if any, is whether the amount included in renegotiable income for the fiscal year ended December 31, 1945, for amounts accrued by Whitin at the close of 1943 and 1944 are subject to renegotiation. Petitioner’s contention, in general, is that the amounts accrued— $119,033 at the close of 1943 and $43,715 at the close of 1944 — were subjected to renegotiation for those years and may not again be renegotiated. Respondent’s answer to the contentions of petitioner is based, first, upon the theory that petitioner was…
2Cases cited1 opinion
- Psaty & Fuhrman, Inc. v. StimsonUnited States Tax Court · 1948
3Cited by16 opinions
- Edell v. United StatesUnited States Tax Court · 1957
- Grumman Aircraft Engineering Corp. v. Renegotiation BoardUnited States Tax Court · 1969
- Hooper Constr. Co. v. Renegotiation BoardUnited States Tax Court · 1961
- R. G. Le Tourneau, Inc. v. Administrator of General ServicesUnited States Tax Court · 1954
- Park Sherman Co. v. United StatesUnited States Tax Court · 1957
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