Gale v. War Contracts Price Adjustment Board
United States Tax Court
Petitioners were the sales representatives of Crucible Steel Company of America under an employment contract entered into in 1935. In the same year they assigned this contract to a wholly owned corporation which performed all services called for thereunder.
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Petitioners were the sales representatives of Crucible Steel Company of America under an employment contract entered into in 1935. In the same year they assigned this contract to a wholly owned corporation which performed all services called for thereunder. This employment contract could have extended to 1961. On December 30, 1943, the employment contract was ended by a cancellation agreement under which petitioners received $ 1,700,000, the corporation having been liquidated immediately prior thereto. Respondent determined $ 225,000 of this amount to be excessive profits. Petitioners contend…
1Opinion of the Court
OPINION.
Withey, Judge:
Petitioners and respondent agree that the employment contract between Crucible and petitioners was subject to renegotiation and under such contract Waters-Vogel renegotiated commission payments totaling $207,409 made during the year 1943. The record shows Crucible was anxious to terminate the employment contract, as a result of which Crucible made an offer of $1,700,000 for cancellation thereof. The petitioners accepted the offer. Respondent determined that $225,000 of the $1,700,000 was excessive profit.
At the outset we should state petitioners have not submitted any…
2Cases cited3 opinions
- Grob Bros. v. Secretary of WarUnited States Tax Court · 1947
- Wolff & Phillips v. MacauleyUnited States Tax Court · 1947
- Providence Wool Combing Co. v. Secretary of WarUnited States Tax Court · 1950
3Cited by2 opinions
- Estate of Robert I. Gale, Deceased, Robert I Gale, Jr., Guy W. Waters and Edgar H. Vogel v. United StatesCourt of Appeals for the D.C. Circuit · 1955
- Gale v. War Contracts Price Adjustment BoardUnited States Tax Court · 1953