Michigan Chemical Corp. v. Renegotiation Bd.
United States Tax Court
Renegotiation -- Exemption. -- Petitioner is a chemical company which in 1957 entered into a contract with the Atomic Energy Commission to process yttrium oxide from a cerain raw material supplied to petitioner by the AEC. In 1961, the Renegotiation Board determined that in the year 1957, petitioner realized excessive profits of $ 250,000 from this contract.
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Renegotiation -- Exemption. -- Petitioner is a chemical company which in 1957 entered into a contract with the Atomic Energy Commission to process yttrium oxide from a cerain raw material supplied to petitioner by the AEC. In 1961, the Renegotiation Board determined that in the year 1957, petitioner realized excessive profits of $ 250,000 from this contract. Held: 1. Petitioner's claim for exemption under sec. 106(a) (3), Renegotiation Act of 1951, is denied. 2. Petitioner realized excessive profits from its contract with the AEC in the sum of $ 250,000.
1Opinion of the Court
OPINION
The sole issue for determination in this case is whether petitioners contract with the AEC to provide yttrium oxide to that agency, such oxide to be derived from a raw material supplied by the AEC, is entitled to exemption under section 106(a) (3) of the Renegotiation Act of 1951, as amended.1 The resolution of this issue hinges on the interpretation of the language “contract * * * for the product of a mine” as it is used in section 106(a) (3).
Briefly stated, the facts that gave rise to this litigation are as follows: Petitioner is a manufacturer of chemicals. In 1956, petitioner…
2Cases cited2 opinions
- Morgan Constr. Co. v. Secretary of WarUnited States Tax Court · 1948
- Lampton's Executors v. Preston's ExecutorsCourt of Appeals of Kentucky · 1829
3Cited by2 opinions
- Michigan Chemical Corp. v. Renegotiation Bd.United States Tax Court · 1968
- Michigan Chemical Corporation v. The Renegotiation BoardCourt of Appeals for the Sixth Circuit · 1969