HOFFMAN v. U.S.

Docket Nos. 466-R, and 610-R.

23 T.C. 569 (1954)

P. R. HOFFMAN AND BERTHA S. HOFFMAN, TRADING AND DOING BUSINESS AS PHILIP MACHINE SHOP, A PARTNERSHIP, PETITIONERS, v. THE UNITED STATES, RESPONDENT.

United States Tax Court.

Filed December 31, 1954.


Attorney(s) appearing for the Case

George F. Smith, Jr., Esq., and James E. Rodgers, Esq., for the petitioners.

Frederick N. Curley, Esq., for the respondent.


These consolidated proceedings involve a determination of the respondent, pursuant to the Renegotiation Act of 1943, that petitioner Philip Machine Shop, a partnership composed of P. Reynold Hoffman and his sister, Bertha S. Hoffman, realized excessive profits for the years 1944 and 1945 in the amounts of $80,000 and $60,000, respectively.

The sole issue to be decided is whether petitioner was "under the control of or controlling or under common control" during the...

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