Pechtel v. United States

OPINION.

Hill, Judge:

The first issue concerns the question whether some form of common control existed between the partnership, Island Machine Tool Company, and the corporation, Island Stamping Company, Inc., so that the sales of each (about $400,000 for each company) may be combined to equal sales in excess of $500,000, thereby subjecting the partnership to renegotiation.1 The question whether or not any two or more business ventures are under common control is a question of fact which must be determined on the basis of all the evidence presented.2

Petitioners contend that their partnership…