Legal Opinion

Northwest Automatic Products Corp. v. United States

United States Tax Court

Decided June 23, 1955No. Docket No. 798-RPublishedCited by 1 opinion

Petitioner prepared and submitted a Standard Form of Contractor's Report for its fiscal year ended December 31, 1944, to Chicago Ordnance Price Adjustment Division (hereinafter called Chicago P. A. D.) on May 4, 1945. The report was completely filed no later than February 11, 1946. On May 8, 1945, Chicago P. A. D. sent a letter to petitioner by regular mail requesting a preliminary conference in respect to renegotiation for petitioner's fiscal year 1944. Subsequently,…

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Petitioner prepared and submitted a Standard Form of Contractor's Report for its fiscal year ended December 31, 1944, to Chicago Ordnance Price Adjustment Division (hereinafter called Chicago P. A. D.) on May 4, 1945. The report was completely filed no later than February 11, 1946. On May 8, 1945, Chicago P. A. D. sent a letter to petitioner by regular mail requesting a preliminary conference in respect to renegotiation for petitioner's fiscal year 1944. Subsequently, Chicago P. A. D. sent petitioner a letter, by registered mail, on May 1, 1946, stating that this letter constituted notice of…

1Opinion of the Court

OPINION.

Fisher, Judge:

The issues presented for our consideration are whether a renegotiation proceeding in respect to petitioner for its fiscal year ended December 31, 1944, was timely commenced or, if so timely commenced, whether it was timely completed in accordance with the provisions of section 403 (c) (3) of the Eenegotiation Act of 1943. Questions raised in connection with these issues are indicated below in the statement of petitioner’s and respondent’s several contentions, and are considered, to the extent required, in our discussion.

The [Renegotiation Act of 1943 (as amended by the…

2Cases cited5 opinions

  1. Block v. CommissionerUnited States Tax Court · 1943
  2. Midtown Catering Co. v. CommissionerUnited States Tax Court · 1949
  3. Buck v. War Contracts Price Adjustment BoardUnited States Tax Court · 1948
  4. United States v. Wissahickon Tool Works, Inc.District Court, S.D. New York · 1951
  5. Oregon Brass Works v. War Contracts Price Adjustment BoardUnited States Tax Court · 1951

3Cited by1 opinion

  1. Northwest Automatic Products Corp. v. United StatesUnited States Tax Court · 1955

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