Edell v. United States
United States Tax Court
1. Held, (a) that contracts between petitioner and each of its several principals provided that petitioner would sell or attempt to sell products of a principal to a department of the Government, and would solicit, attempt to procure, and procure Government contracts for a principal; and (b) that under each of such contracts petitioner's compensation for its services was contingent upon the procurement of a Government contract; and that, therefore, (c) each of the contracts…
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1. Held, (a) that contracts between petitioner and each of its several principals provided that petitioner would sell or attempt to sell products of a principal to a department of the Government, and would solicit, attempt to procure, and procure Government contracts for a principal; and (b) that under each of such contracts petitioner's compensation for its services was contingent upon the procurement of a Government contract; and that, therefore, (c) each of the contracts between petitioner and its principals was a subcontract within the provisions of section 403 (a) (5) (b) (i) and (ii) of…
1Opinion of the Court
OPINION.
Harron, Judge:
The first issue presents the problem whether any of the Edell partnership’s earnings for each of the 3 years, 1943-1945, inclusive, is subject to renegotiation under the provisions of section 403 (a) (5) (B) of the Renegotiation Act of .1942, as amended.2 If that issue is decided in the affirmative, another question must be decided, the amount in each year of the partnership’s excessive profits, if any, under the provisions of section 403 (a) (4) (A). It is now well established that in a Tax Court proceeding for the redetermination of excessive profits the petitioner has…
2Cases cited8 opinions
- Cohen v. Secretary of WarUnited States Tax Court · 1946
- Rosner v. War Contracts Price Adjustment BoardUnited States Tax Court · 1951
- Greaves v. War Contracts Price Adjustment BoardUnited States Tax Court · 1948
- Wolff & Phillips v. MacauleyUnited States Tax Court · 1947
- Bass v. StimsonUnited States Tax Court · 1953
3 more not listed; retrieve them via the Exa API.
3Cited by7 opinions
- Golbert v. Renegotiation BoardUnited States Tax Court · 1957
- Beets v. Renegotiation BoardUnited States Tax Court · 1962
- Beets v. Renegotiation BoardUnited States Tax Court · 1962
- Beets v. Renegotiation BoardUnited States Tax Court · 1962
- Edell v. United StatesUnited States Tax Court · 1957
2 more not listed; retrieve them via the Exa API.