STEWART DICKSON & CO. v. UNITED STATES MARITIME COMMISSION

Docket No. 435-R.

12 T.C. 482 (1949)

STEWART DICKSON & COMPANY, STEWART DICKSON AND MARY E. DICKSON, HIS WIFE, GUIDO RUGGIERO, JOHN S. BENNETT & ELSIE E. BENNETT, HIS WIFE, AND EMMA THOMPSON, PARTNERS, FORMERLY DOING BUSINESS UNDER THE FIRM NAME AND STYLE OF STEWART DICKSON & COMPANY, PETITIONERS, v. UNITED STATES MARITIME COMMISSION, RESPONDENT.

United States Tax Court.

Promulgated March 29, 1949.


Attorney(s) appearing for the Case

Stephen Walter, Esq., for the petitioners.

Paul L. Muilenburg, Esq., for the respondent.


OPINION.

MURDOCK, Judge:

A unilateral determination was made that profits of the petitioner partnership in the amount of $180,000 for the fiscal year ended May 31, 1943, on contracts or subcontracts subject to renegotiation, were excessive. The only questions urged for decision are whether the Renegotiation Act of 1942 applied to the royalties received by the partnership from contractors or subcontractors whom it had licensed to use a patent, and...

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