Stow Mfg. Co. v. Commissioner
United States Tax Court
On June 1, 1943, petitioner entered into a final renegotiation agreement with the Secretary of the Navy in which it was agreed that its excessive profits were $ 350,000 and should be paid, $ 70,000 in cash and $ 280,000 by an excess profits tax credit under section 3806 (b) (1), I. R. C. This $ 280,000 excess profits tax credit was erroneous and should have been $ 252,000. Notwithstanding the error the renegotiation agreement, by its very terms, could not be reopened.
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On June 1, 1943, petitioner entered into a final renegotiation agreement with the Secretary of the Navy in which it was agreed that its excessive profits were $ 350,000 and should be paid, $ 70,000 in cash and $ 280,000 by an excess profits tax credit under section 3806 (b) (1), I. R. C. This $ 280,000 excess profits tax credit was erroneous and should have been $ 252,000. Notwithstanding the error the renegotiation agreement, by its very terms, could not be reopened. On May 20, 1948, respondent determined a deficiency in petitioner's excess profits tax by eliminating from petitioner's gross…
1Opinion of the Court
Stow Manufacturing Company, Inc., Petitioner, v. Commissioner of Internal Revenue, Respondent
Stow Mfg. Co. v. Commissioner
Docket No. 19923
United States Tax Court
14 T.C. 1440; 1950 U.S. Tax Ct. LEXIS 144;
June 30, 1950, Promulgated
Decision will be entered for the respondent.
On June 1, 1943, petitioner entered into a final renegotiation agreement with the Secretary of the Navy in which it was agreed that its excessive profits were $ 350,000 and should be paid, $ 70,000 in cash and $ 280,000 by an excess profits tax credit under section 3806 (b) (1), I. R. C. This $ 280,000 excess profits tax…
2Cases cited3 opinions
- Baltimore Foundry & Machine Corp. v. CommissionerUnited States Tax Court · 1946
- Maguire Indus. v. Secretary of WarUnited States Tax Court · 1949
- Stow Mfg. Co. v. CommissionerUnited States Tax Court · 1950