Infobox SCOTUS case Litigants ThorPowerToolCompanyv. Commissioner ArgueDate November 1 ArgueYear 1978 DecideDate January 16 DecideYear 1979 FullName ThorPowerToolCompanyv. Commissioner of Internal Revenue USVol 439 USPage 522 Citation 439 U.S. 522 Prior Subsequent Holding The Commissioner did not abuse his discretion in determining that the write down of excess inventory failed to reflect petitioner s 1964 income clearly, since the write down was plainly inconsistent with the governing Regulations. SCOTUS 1975 1981 Majority Blackmun JoinMajority unanimous court LawsApplied In ThorPowerToolCompanyv. Commissioner , Case citation 439 U.S. 522 1979 the Supreme Court of the United States United States Supreme Court upheld IRS regulations limiting how taxpayers could write down inventory. The opinion limited the application of the lower of Cost or Market method to the two circumstances in the regulations. The taxpayer had reduced the value of its inventory to an amount management asserted was the fair market value, without selling the inventory. In court, the taxpayer argued that its deduction for loss should be allowed for tax purposes because it was permitted for accounting purposes. The Court stated, There is no presumption that an inventory practice conformable to generally accepted accounting principles is valid for tax purposes. Such a presumption is insupportable in light ... ThorPowerTool Co. v. Commissioner, 439 U.S. 522 1979 findlaw http laws.findlaw.com us 439 522.html justia http supreme.justia.com us 439 522 case.html References Reflist DEFAULTSORT ThorPowerToolCompanyV. Commissioner Category United States Supreme Court cases Category United States taxation ... to support its loss. Thor manufactured equipment using multiple parts that it produced. It capitalized ... was in accordance with the company s accounting practice. IRS regulations provided that goods could ... price, or the goods were defective or subnormal . The Court denied the write down because Thor did ... more details
Infobox SCOTUS case Litigants Commissionerv. Indianapolis Power & Light Company ArgueDate October 31 ArgueYear 1989 DecideDate January 9 DecideYear 1990 FullName Commissioner of Internal Revenue v. Indianapolis Power & Light Company USVol 493 USPage 203 Citation 110 S.Ct. 589, 107 L.Ed.2d 591 1990 Prior 88 T.C. 964 1987 , affirmed by 857 F.2d 1162 7th Cir. 1988 Subsequent Holding Because customers were entitled to a refund of their deposit, the utility lacked complete dominion over the funds, so the deposits did not constitute taxable income to the utility. SCOTUS 1988 1990 Majority Blackmun JoinMajority Rehnquist, Brennan, White, Marshall, Blackmun, Stevens, O Connor, Scalia, Kennedy LawsApplied In Commissionerv. Indianapolis Power & Light Company 493 U.S. 203 1990 , the United States Supreme Court addressed whether customer deposits constituted taxable income to a public utility company. Facts Indianapolis Power & Light Company IPL required customers with suspect credit to make deposits with it to assure payment of future bills for electric service. IPL paid interest on deposits held for a certain period of time. A customer could obtain a refund prior to termination of service by making on time payments or by demonstrating acceptable credit. The refunds were normally made in cash or by check but a customer could also choose to have the deposit amount applied against future bills. Any deposit unclaimed after seven years would escheat to the State. At the time of receipt, IPL did not treat the deposits as income for tax purposes. The Internal Revenue Service IRS audited the utility and assessed a tax deficiency. IPL appealed this assessment to the United States Tax Court , which sided with IPL. This decision was then appealed, eventually reaching the Supreme Court. Analysis ... in the United States DEFAULTSORT CommissionerV. Indianapolis Power & Light Co. Category United ... dominion constitute income . Commissionerv. Glenshaw Glass Co. , 348 U.S. 426, 431 1955 . The Court ... more details
cleanup date October 2008 expert subject multiple U.S. Supreme Court cases Law date October 2008 Infobox SCOTUS case Litigants Commissioner v. Idaho Power Co. ArgueDate February 27 ArgueYear 1974 DecideDate June 24 DecideYear 1974 FullName Commissioner of Internal Revenue v. Idaho Power Co. USVol 418 USPage 1 Citation Prior Subsequent Holding SCOTUS 1972 1975 Majority Blacknum JoinMajority Burger, Brennan, Stewart, White, Marshall, Powell, Rehnquist Dissent Douglas LawsApplied Commissioner v. Idaho Power Co. , 418 U.S. 1 1974 Facts Taxpayer , Idaho Power Co., used its own equipment and employees to improve and add to its capital facilities . On its books, Idaho Power capitalized the construction related depreciation on this equipment used for construction of the capital asset . But for income tax purposes, the taxpayer deducted the entire amount of depreciation on equipment used in construction of the capital asset under 167 a including the amount capitalized as construction costs. Issue Whether, for federal income tax purposes, a taxpayer is entitled to a deduction from gross income under 167 a of the Code for depreciation on equipment the taxpayer owns and uses in the construction of its own capital facilities, or whether the capitalization provision of 263 a 1 of the Code bars the deduction Rule Construction related expense items, such as tools, materials, and wages to construction workers are treated as part of the cost of acquisition of a capital asset. Reasonable wages paid in carrying on of a trade or business qualify as a deduction from gross income, but when wages are paid in connection with construction or acquisition of a capital asset they must be capitalized and are then entitled to be amortized over the life of the capital asset so acquired. 263 a 1 of the Internal Revenue Code denies a deduction for any amount paid out for construction or permanent improvement of facilities. This extends to the cost of acquisition, construction, or erection of buildin ... more details
SCOTUSCase Litigants Minneapolis Star Tribune Companyv. Commissioner ArgueDate January 12 ArgueYear 1983 DecideDate March 29 DecideYear 1983 FullName Minneapolis Star Tribune Companyv. Commissioner USVol 460 USPage 575 Citation 75 L. Ed.2d, 103 S. Ct. 1365 1983 Prior 314 N.W.2d 201 Min. 1981 Subsequent Holding Special taxes imposed on ink and paper are unconstitutional under the First Amendment. ref http caselaw.lp.findlaw.com scripts getcase.pl?navby CASE&court US&vol 460&page 575 Full text of the opinion on Findlaw.com ref SCOTUS 1981 1986 Majority O Connor JoinMajority Brennan, Marshall, Blackmun, Stevens, Powell Concurrence White concurring in part, dissenting in part Dissent Rehnquist LawsApplied First Amendment to the United States Constitution U.S. Const. amend. I Minneapolis Star Tribune Companyv. Commissioner , ussc 460 575 1983 , was an opinion of the Supreme Court of the United States overturning a use tax on paper and ink in excess of 100,000 consumed in any calendar year. On its face, this ruling finds that state tax systems cannot treat the press differently than any other business without significant and substantial justification. The state of Minnesota demonstrated no such justification to impose a special tax on a select few newspaper publishers. Therefore, this tax was in violation of the First Amendment to the United States Constitution First Amendment s guarantee of freedom of the press . Related Cases Grosjean v. American Press Co. National Association for the Advancement of Colored People v. Button Arkansas Writers Project, Inc. v. Ragland Leathers v. Medlock Turner Broadcasting System v. Federal Communications Commission See also Freedom of the press List of United States Supreme Court cases, volume 460 Further reading cite book title Freedom of the press ... Star Tribune Companyv. Commissioner , 460 U.S. 575 1983 findlaw http laws.findlaw.com us 460 575.html ... Minneapolis Star Tribune CompanyV. Commissioner Category 1983 in United States case law Category ... more details
Infobox Court Case name Midland Empire Packing Companyv. Commissioner of Internal Revenue court United States Tax Court image imagesize imagelink imagealt caption full name date decided April 19, 1950 citations 14 T.C. 635 transcripts judges Arundell prior actions subsequent actions opinions The Tax Court found that the taxpayer could deduct the cost of lining the walls in the basement of his business to prevent oil from seeping in because, in doing so, the taxpayer did not add value to his business but merely returned it to its original useful value. keywords Midland Empire Packing Companyv. Commissioner. , Case citation 14 T.C. 635 1950 , was a case in which the United States Tax Court ruled that Midland Empire Packing Company was permitted to deduct the costs of lining its basement walls and floor. The costs were held to be repairs, and thus deductible as an ordinary and necessary business expense under section 162 a of the Internal Revenue Code. Facts The petitioner, Midland Empire Packing Company Midland , was the owner of a meat packing plant in the State of Montana . The basement ... sdt 2,39&case 7013400987329848575&scilh 0 title Google Scholar Midland Empire Packing Co. v. COMMISSIONER .... The Internal Revenue Commissioner concluded that the cost of oilproofing was a non deductible capital ... challenged the Commissioner s finding in The United States Tax Court. Opinion of the Court In an opinion ... wvxHCSUQAB&dq Midland 20Empire 20Packing 20Company 20v. 20Commissioner&pg SA4 PA6 v onepage&q &f ... proofing merely allowed Midland to continue its original operations. Expenditure was Necessary The Commissioner ... was Ordinary The Commissioner argued that the expenditure was not ordinary within the meaning of section 23 a . Judge Arundell, in rejecting this argument, quoted Welch v. Helvering , 290 U.S. 111, noting ... and accepted means of defense against attack . Cf. Kornhauser v. United States, 276 US 145 ... 1&oi scholarr Kornhauser v. United States, 276 U.S. 145 title Google Scholar Kornhauser v. United ... more details
Electric ToolCompany . ref cite book last Nagyszalanczy first Sandor title Power Tools ...cleanup date October 2009 Refimprove date August 2009 A powertool is a tool that is actuator actuated by an additional engine power source and mechanism engineering mechanism other than the solely manual labour used with hand tool s. The most common types of power tools use electric motor s. Internal combustion engine s and compressed air are also commonly used. Other power sources include steam engine s, direct burning of fuels and propellants, ref e.g. in powder actuated tool s ref or even natural power sources like wind power wind or hydropower moving water . Tools directly driven by animal power are not generally considered power tools. Power tools are used in industry, in construction , and Do ... held power saw. ref and some stationary power tools can produce objects that cannot be made in any other way. ref e.g. lathe tool lathe s produce truly round objects ref Stationary power tools for metalworking ... woodworking and metalworking. The term powertool is also sometimes used as a buzzword , meaning a technique ... Bosch GmbH was one of the first companies to introduce a powertool housing made of glass filled ... Jigsaw powertool Jigsaw Lathe tool Lathe Miter saw Nail gun electric and battery as well as powder actuated Needle scaler Pneumatic torque wrench Powder actuated tool s Power wrench Radial arm saw ... Cutting tool Diamond tool Garden tool Hand arm vibrations Hand tool Metalworking NIOSH Power Tools ... Tools. http wwwn.cdc.gov niosh sound vibration NIOSH PowerTool Sound and Vibrations Database http ... Powertool manufacturers Category Woodworking hand held power tools Category Woodworking machines Category ..., sander sanding , grinding, wood router routing , polishing, painting, heating and more. Power tools are classified as either stationary or portable, where portable means hand held. Portable power tools have obvious advantages in mobility. Stationary power tools however often have advantages ... more details
Infobox SCOTUS case Litigants American Electric PowerCompanyv. Connecticut ArgueDate April 19 ArgueYear 2011 DecideDate June 20 DecideYear 2011 FullName American Electric PowerCompany, Inc., et al., v. Connecticut Docket 10 174 Citation Prior Complaints dismissed, 406 F.Supp.2d 265 S.D.N.Y. 2005 vacated and remanded on appeal, 582 F.3d 309 2nd Cir 2009 certiorari granted, 2010 WL 4922905. Subsequent Holding Reversed and Remanded unanimous ruling, 8 0 FullName American Electric Power Co., Inc. v. Connecticut SCOTUS 2010 2012 Majority Ginsburg JoinMajority Roberts, Scalia, Kennedy, Breyer, Kagan Concurrence Alito JoinConcurrence Thomas NotParticipating Sotomayor OralArgument American Electric PowerCompanyv. Connecticut , Case citation 564 U.S. 2011 , is a United States Supreme Court case. Although the case is about whether states can seek to curtail greenhouse gas emissions from utilities across state borders using federal common law theories of interstate nuisance, the ultimate issue facing the Court was whether climate change regulations and related issues can be decided through the court system while the EPA is finalizing regulations that the Court previously held the United States Environmental Protection Agency Environmental Protection Agency must issue see Massachusetts v. Environmental Protection Agency . Opinion of the Court On Monday, June 20, 2011, the Supreme Court issued a unanimous decision Justice Sotomayor recused herself . The Court held that until and unless the EPA acts inappropriately or errs e.g. when it finally issues its mandated regulations in 2012 , the EPA and the equivalent agencies at the state and local level, to the extent allowed under the law is responsible not the courts for overseeing and enforcing any regulations or changes to the regulations ... Appeals Court s opinion in the case http www.scotusblog.com case files cases american electric power co inc v connecticut 2 Coverage of the case by SCOTUSblog http www.onthedocket.org articles 2010 ... more details
Infobox power station name Thor Cogeneration Power Station image Model .jpg image caption The proposed Thor Cogeneration Power Station location map County Durham lat d 54.603145 long d 1.202748 country England locale County Durham , North East England operator PX Limited primary fuel Natural gas fired primary fuel capacity 1,020  MW commissioned 2012 decommissioned extra gbmapping NZ516234 Not to be confused with Seal Sands Power Station Thor Cogeneration is a planned Natural gas gas fired Cogeneration cogeneration plant , which is to be built on Seal Sands near Billingham , in County Durham , North East England . Development On 19 January 2007, newly established business venture Thor Cogeneration, a subsidiary of Teesside based PX Group, announced plans for a new power station on Teesside . ref name unveiled cite web url http www.thenorthernecho.co.uk business 1136574.plans unveiled to build green gaspowered station title Plans unveiled to build green gas powered station date 20 January 2007 work The Northern Echo accessdate 11 June 2010 ref The station is proposed as a 1,020 megawatt MW combined heat and power combined cycle gas turbine plant. ref name brochure Stockton Borough Council gave their approval for the station in April 2007. The station s license for the generation of electricity was also granted later in 2007. ref name welcomed On 28 August 2008, government approval ... news.asp?id 5630 title Thor gets green light to build CHP station date 28 August 2008 work http www.heatingandventilating.net ... view 36 53 title Power plant decision welcomed accessdate 2009 01 01 date 28 August 2008 work ... than current coal fired power stations. ref name green light It will be cooled by using an air ... North East Power Stations Category Power stations in North East England Category Buildings and structures in County Durham Category Proposed natural gas fired power stations Category Proposed power stations in the United Kingdom no Thor Cogen gasskraftverk ... more details
File Decoupeerzaag.jpg thumb A power jigsaw File Jigsaw saws.jpg thumb A T fixture blades A jigsaw is a tool used for cutting arbitrary curve s, such as stencil ed designs or other custom shapes, into a piece of wood , metal , or other material. It can be used in a more art istic fashion than other saws, which typically cut in straight lines only. In this way, it is similar to the rasp and the chisel . Although a jigsaw can be used to cut arbitrary patterns, making a straight cut freehand is difficult even with a guide. Traditional jigsaws are hand saw s, consisting of a handle attached to a small, thin blade. The first jigsaw puzzle s were made using this kind of unpowered saw. More modern jigsaws are powertool s, made up of an electric motor and a reciprocating saw blade . A jigsaw with a bevel function on the sole plate allows cutting angles of typically up to 45 degrees relative to the normal vertical stroke for cutting miter joint s. In the past, what are now usually called scroll saw s were often referred to as jigsaws. A jigsaw may also be referred to, by some manufacturers, as a bayonet saw . History The first powered jigsaw was created in 1946 when Albert Kaufmann, an engineer of Scintilla AG company in Solothurn , Switzerland , replaced the needle on his wife s sewing machine with a saw blade. ref http www.bosch presse.de TBWebDB en US PressText.cfm?CFID 2011027&CFTOKEN 446645a8b43a1652 DD6E7392 C02B 8FEF 4C5A7C33F8BACAA8&Search 1&id 3194 Bosch Media Service ref ref http www.asktooltalk.com articles toolhistory jigsaw.php Invention of the Jigsaw ref ref http www.bosch presse.de TBWebDB en US Presstext.cfm?CFID 966836&CFTOKEN cece6a5aa499beb 5E99CC9E F1AA 6F6B 6979F2BF6B0F7136 ... the pendulum action to the blade movement and in 1989 it added the tool less blade replacement device ... NIOSH Power Tools Sound and Vibrations Database Types of tools Woodworking Category Metalworking cutting tools Category Saws Category Woodworking hand held power tools da Stiksav de Stichs ge et Tikksaag ... more details
Unreferenced date December 2009 Infobox album See Wikipedia WikiProject Albums Name PowerTool Stigmata Type studio Artist Godhead band Godhead Cover PowerTool Stigmata.jpg Released March 17, 1998 Recorded 1998 Genre Industrial rock Length 59 44 Label Sol 3 Producer Richard Gottehrer Reviews Last album Nothingness Godhead album Nothingness br 1997 This album PowerTool Stigmata br 1998 Next album 2000 Years of Human Error br 2001 PowerTool Stigmata is the third studio album by the United States American Rock music rock band Godhead band Godhead . It was released on March 17, 1998 by Sol 3 Records. The album contains select songs that have since been re recorded by the band for subsequent releases including 2000 Years of Human Error and Unplugged EP Unplugged . Track listing All songs by Jason C. Miller and Method Godhead Ullrich Method Hepperlin except where noted. Gimp 3 33 Penetrate 4 44 Eleanor Rigby 3 43 Lennon McCartney Alone 5 08 Method, Miller, Miller Bleed 3 43 Fucked Up 4 44 Method Craving 4 07 Method, Miller, Miller Laura s Theme 3 25 Method Lies 4 30 Method, Miller, Miller Memorial 5 03 Headache Symphony 3 32 Method Suffer 4 04 Pride 5 43 Method, Miller, Miller Afterthoughts 3 40 Personnel Jason C. Miller singing vocals , rhythm guitar , Audio mixing recorded music mixing Mike Miller lead guitar , backing vocals Method Godhead Ullrich Method Hepperlin Bass guitar bass , keyboard instrument , Programming music programming , mixing, engineering James O Connor drummer James O Connor drums Richard Gottehrer Music producer producer Doug Milton editing John Serv o DeSalvo programming Jeffrey Lesser mixing, engineering Pete Evick mixing, engineering Drew Mazurek mixing Steve Fallone Audio mastering mastering Weld engineering DEFAULTSORT PowerTool Stigmata Album Category 1998 albums Category Godhead albums 1990s alt rock album stub ... more details
p 12 . ref E.P. Bullard Jr led the development of the company s multiple Spindle tool spindle Visible ... Jr was president of the company for 40 years, through World War I , the interwar period , and World War II , a period during which the Bullard company was the largest machine tool builder in the U.S. ... PA113 v onepage&f false pp. 113 114 ref . He received formative experience at Colt s Manufacturing Company the Colt armory and Pratt & Whitney Measurement Systems Pratt & Whitney , ref name Day etal 1996pp113 114 which were influential development centers for generations of Tool and die maker ... PA174 v onepage&q &f false p. 174 ref Bullard Sr is believed to have developed the first small Boring ... , http books.google.com books?id X EJAAAAIAAJ&pg PA184 v onepage&q &f false p. 184 ref Roe 1916 ... Bullard Sr s son, Edward Payson Bullard Jr 1872 1953 , continued the family machine tool business ... first Henry D. coauthors Axelrod, Aaron, and Anderson, James year 1959 title Machine Tool Operation ... Precision Museum title Edward P. Bullard 1872 1953 work Machine Tool Hall of Fame publisher American ... Machine tool builders ... more details
OTC ToolCompany was founded in Owatonna, Minnesota by Reuben A. Kaplan in 1925. Automobiles were new with few tools created for them yet. Kaplan, who operated a small machine shop, invented the Grip O Matic universal gear puller and received his first patent. ref http www.google.com patents?vid USPAT1709913 Rueben A. Kaplan of Owatonna, MN, Assignor to Owatonna Tool Co of Owatonna, Minnesota, a Minnesota Corporation Gear Puller , Google Patents , 1929 04 23, Retrieved on 2011 04 12. ref The tool remains virtually unchanged to this day. ref http home.comcast.net alloy artifacts owatonna tool company.html Owatonna ToolCompany , Alloy Artifacts , 2009 06 05, Retrieved on 2011 04 12. ref By 1934, OTC was selling a variety of mechanic s tools to farmers and service stations. The tools were sold directly to the customer from makeshift display boards fitted into Panel truck panel trucks or converted autos. When World War II broke out in 1939, the U.S. Army and Navy bought large quantities of OTC tools and by 1945, the company had doubled its staff. In 1950, Kaplan began work in ultra high pressure fluid power technology, a new technology for hydraulics manufacturers of the day. One development was a twin cylinder ram that operated at 10,000 psi much higher than any other devices of the day. ref http www.counterman.com Article 8135 otc celebrates 85 years of innovation.aspx OTC Celebrates 85 Years of Innovation , The Counter Man , 2010 11 05, Retrieved on 2011 04 12. ref By 1985, OTC had an extensive line of tools and systems for both OEM and Aftermarket automotive aftermarket customers. That success led to its acquisition by Sealed Power Corporation now SPX Corporation of Muskegon, MI . ref http www.fundinguniverse.com company histories SPX Corporation Company History.html SPX Corporation , Funding Universe , Retrieved on 2011 04 12. ref OTC is a global supplier of Electronic control unit vehicle electronic diagnostic instruments fuel systems service tools special service ... more details
Refimprove date December 2009 Hughes ToolCompany was established in 1908 as Sharp Hughes ToolCompany ... Aircraft Company as a division of the Hughes ToolCompany. Hughes Aircraft thrived on wartime ... 1972 10 24 fdate 1971 04 05 inventor Edward M. Galle invent1 Galle, Edward M. assign1 Hughes ToolCompany ..., Howard Hughes sold the Hughes ToolCompany it had been the consistently profitable part of his ... Hughes ToolCompany while the remaining divisions of the business were placed in a new holding company ... established in 1908 Category 1908 establishments in the United States de Hughes ToolCompany fr Hughes ToolCompany tr Hughes ToolCompany ... to manufacture and market the bit. Sharp s widow, Estelle Sharp, sold her 50 share in the company to Howard Hughes Sr. following her husband s death in 1912. The company was renamed Hughes Tool at this point. When Hughes Sr. died in 1924, 75 of the company was left to Howard Hughes Howard Hughes ... Jr. s ownership, Hughes Tool ventured into the motion picture business via Hughes Productions ... company and was donated to the Howard Hughes Medical Institute as its endowment. Hughes Aircraft s helicopter manufacturing business was retained by Hughes Tool Co. as its Aircraft Division until 1972. For a period of time in the 1940s to late 1950s, Hughes Tool owned the RKO companies, including ... 1960s, Hughes Tool held a minority stake in Northeast Airlines . Hughes Tool s majority stake in TWA was sold off in 1966. Two years later, in 1968, Hughes ToolCompany purchased the North Las Vegas Airport North Las Vegas Air Terminal . In the late 1960s, Hughes Tool ventured into the hotel ... Inn , all in Las Vegas, Nevada Las Vegas . Hughes Tool also purchased KLAS TV , Las Vegas CBS affiliate. In the early 70 s, Hughes Tool ventured back into the airline industry with the takeover ... following the purchase. Hughes Tool also briefly owned Los Angeles Airways , a small airline operating ... more details
Orphan date February 2009 Infobox company name Pacific ToolCompanycompany logo Image pacific.jpg type Private foundation 1920s location city Grand Island location country United States location locations key people area served California , Nebraska industry Reloaders products Shotshell and Rifle Presses services revenue operating income net income num employees parent Pacific Gun Sight Co. divisions subsid slogan homepage http pacificreloaders.awardspace.com dissolved 1992 footnotes intl Pacific ToolCompany is an alternative energy and generator distributor in Riverside, CA that can be found at www.PacificToolCompany.com Pacific ToolCompany is an authorized Kubota Dealer and specializes in Solar Panels, Solar Inverters and 5KW to 100KW Wind Turbines. Previously, Pacific ToolCompany was a major reloading company from the 1950s to the 1990s. Many of these reloaders show up on the market because they are built to last and are very dependable. Although these reloaders have not been manufactured since 1992, they are still highly sought after products. History The Pacific ToolCompany started off as the Pacific Gunsight Company, which opened its doors in the early 1920s at 353 Hays St, San Francisco, California. In 1953 they moved to 2901 El Camino Real, Palo Alto, Calif. Pacific was then sold to Henkle & Joyce Hardware of Lincoln NE. R.R. Deitemeyer had convinced H&J to buy the company and he invented the Deitemeyer shotshell loaders, hence the DL in model descriptions. The tool colors changed to blue with the move from California to P.O. Box 4495 Lincoln, Nebraska in 1960. While in Lincoln, Pacific tools were made by Bair Machine Company until there was a parting of the ways ... 1971 H&J sold Pacific Gunsight Co. dba Pacific ToolCompany to J. W. Hornady. All tools were converted ... with the automatic power of the hydraulic pump. The hydraulic pump was included with the reloader ... to accept a hydraulic unit to power the press. For reloading information, visit http pacificreloaders.awardspace.com ... more details
mergefrom Power Surge comics discuss Talk PowerCompanyPower Surge date June 2009 dablink This is about the comic. For a company that is responsible for generating electricity, see electrical power industry . Superteambox Wikipedia WikiProject Comics image Powercompany.png imagesize caption The PowerCompany br Art by Tom Grummett . team name PowerCompany publisher DC Comics debut Justice League ... initiated by the Society and returned to their base of operations. The PowerCompany make a brief one ... to the forgotten, but not gone PowerCompany. Justice League of America Recently, the team appeared ... that all of the PowerCompany members are currently hospitalized, and that Josiah would ve died had Mon El not forced open his rib cage in order to help treat his heart. Members The PowerCompany ... powerful member of PowerCompany, but rarely accompanies the team in the field. The exact nature ... the credibility to the PowerCompany. Witchfire DC Comics Witchfire Rebecca Carstairs Partner. A magic .... The Nuclear Man briefly joined the powercompany, but left before the end of the series. Sapphire ... Company song PowerCompany , a song by Eric Burdon References Reflist External links http www.mykey3000.com cosmicteams cosmic powercompany.html Cosmic Teams PowerCompany Chronology http www.dcuguide.com who.php?name powercompany DCU Guide PowerCompany http www.dcuguide.com who.php?name silvershannon ... Francisco members Bork comics Bork br Firestorm Ronald Raymond Firestorm br Josiah Power br Manhunter ... Z br Witchfire DC Comics Witchfire memberlist subcat DC Comics hero y villain sortkey PAGENAME The PowerCompany was a team of professional superhero es for hire in the DC Comics universe. The team, created ... 2002 to September 2003 in comics 2003 , also written by Busiek. History Josiah Power was one of America ... Josiah Power Biography Bot generated title ref Following the untimely public activation of his Metahuman metagene in the courtroom , Lawyer attorney Josiah Power is dismissed from his law firm . Power ... more details
Atlas Press Co. was a toolcompany that manufactured popular brands of metalworking tools from 1920 to the mid 1970s. Many of their products received wide coverage in Popular Mechanics and Popular Science at the time. ref name albrecht cite web url http www.petealbrecht.com atlasmillshaper atlasmillshaper.htm title Atlas mill and shaper resources first Peter last Albrecht accessdate 2009 02 21 date 2008 12 ref History In 1911, the inventor Gardner T. Eames of Kalamazoo, Michigan filed for a patent ref Cite patent inventor last Eames inventor first Gardner T. publication date Aug 28, 1914 issue date Oct 10, 1916 country code US title ...a mandrel press having an improved ram driving mechanism ... which is comparatively economical in structure, is very powerful, and one in which the parts are so disposed that the strain thereon is very effectively distributed and well balanced. patent number ... partnered with Herbert H. Everard to create the G.T. Eames Company , under the agreement that the rights to the patent were to be shared between both men. The company started producing the press under ... s handling of the company and sold his shares to them for 5,000. Penniman subsequently moved the company to another location in Kalamazoo, renaming it to Atlas Press Company . Eames opened ... lawsuit against Eames Atlas Press Co. v. Eames , claiming rights over the trademark , patent and improved ... had to cease use of the trademark, but refusing the transfer of the improved press to the Atlas company. ref Michigan Reports, pp. 586 594 ref Later years In 1920 the company began making and selling ... title AtlasHistory accessdate 2009 02 20 first Richard last Stines ref In 1965, the company changed ... product lines to focus on industrial machinery. Today the company operates out of Goshen, Indiana ... three companies ref http www.600group.com about us company history 600 Group company history ref ... home The 600 Group Category Machine tool builders Category Defunct companies based in Michigan Category ... more details
Infobox nrhp name Rhode Island ToolCompany nrhp type image Providence Tool Co.jpg caption location Providence, Rhode Island lat degrees 41 lat minutes 50 lat seconds 36 lat direction N long degrees 71 long minutes 24 long seconds 56 long direction W locmapin Rhode Island area built 1853 architect architecture No Style Listed added August 4, 2004 governing body Private refnum 04000808 ref name nris NRISref 2007a ref Rhode Island ToolCompany is a historic building at 146 148 West River Street in Providence, Rhode Island . The building was built in 1853 and added to the National Register of Historic Places in 2004. References reflist See also National Register of Historic Places listings in Providence, Rhode Island Registered Historic Places Category Buildings and structures completed in 1853 Category Industrial buildings and structures on the National Register of Historic Places in Rhode Island Category Buildings and structures in Providence, Rhode Island RhodeIsland NRHP stub ... more details
Orphan date February 2009 Infobox Companycompany name ATC Automation company logo Image Automation ToolCompany Logo.png 230px Automation ToolCompany logo company type Private slogan Automation Specialists foundation 1977 location Cookeville , Tennessee key people Bill Curran , President Gene Bressler , VP Marketing & Sales num employees 140 2008 products Industrial Automation , Testing Systems homepage http www.automationtool.com www.automationtool.com ATC Automation is a global provider and integrator of custom automation , functional & leak test systems , manual work cells and lean manufacturing solutions. ATC has a significant presence in the energy, medical, consumer products, and automotive markets. The company is headquartered in Cookeville, Tennessee , in a convert 134000 sqft m2 adj on facility that includes a clean facility. ATC employs 150 professionals, including engineer s, craftsmen , specialists and designers. ATC is a certified ISO 9001 2000 company, and stays current on industry standards like GAMP5, DQ IQ OQ PT and Occupational Safety and Health Administration OSHA Cadmium Exposure Standard regulations. External links http www.automationtool.com Automation ToolCompany Web site http www.tasigroup.com TASI Group References ATC Automation. Assembly. BNP Media. 2005. Retrieved November 17, 2008 from HighBeam Research http www.highbeam.com doc 1G1 134990499.html http www.highbeam.com doc 1G1 134990499.html http www.thomasnet.com profileinfo.html?cov NA&which comp&what automation tool company&searchpos 4&cid 935871&navsec results ThomasNet Profile Category Companies established in 1977 Category Companies based in Tennessee ... more details
Use dmy dates date February 2011 Infobox company name The Churchill Machine ToolCompany Limited logo File The Churchill Machine Tool Company.JPG 200px type Machine Tool Manufacturer genre fate Taken over, liquidated, name re used predecessor None successor Alfred Herbert company Alfred Herbert foundation 1901 separate company from 1906 founder Charles Churchill defunct location city Manchester, lastly ..., then Birmingham Small Arms Company BSA and lastly Alfred Herbert divisions subsid homepage http www.churchill grinders.co.uk footnotes intl The Churchill Machine ToolCompany Limited began as the manufacturing ... tool importers Charles Churchill & Company Limited founded in the early 1900s by US born Charles ... a limited company in 1889. In 1906 a separate company, The Churchill Machine Tool Co Ltd, was established ... of that company. He remained chairman of The Churchill Machine Tool Co Ltd and the two companies ... resources. The Churchill Machine Tool Co Ltd was taken over by the Birmingham Small Arms Company which merged with Alfred Herbert company Alfred Herbert Ltd , with production moving to Coventry ... corporate process. A company using The Churchill Machine Tool Co Ltd name still trades but Charles ... Machinist of June 1897. They include the Hamilton Machine ToolCompany of Ohio who were ... toolcompany had a sales agent in Australia by 1932. ref cite news first last authorlink author ... American machine tools under licence, rather as the machine toolcompany had started out in the early ... bankruptcy of Charles Churchill, the company developed to become one of the largest British importers ... Machine Tool Co Ltd relocated its factories onto a single site at Broadheath, Greater Manchester ... Machine Tool Co Ltd ceased trading in the early 1970s along with several other companies ... for a Century Aspects of the machine tool and other industries in Broadheath, Altrincham last1 Sparkes ... at this time. In its early years the company traded from 28 Wilson Street, Finsbury sales catalogues ... more details
Infobox nrhp name American Watch ToolCompany nrhp type image WalthamMA AmericanWatchToolCompany.jpg caption location Waltham, Massachusetts lat degrees 42 lat minutes 22 lat seconds 18 lat direction N long degrees 71 long minutes 13 long seconds 56 long direction W locmapin Massachusetts area built 1877 architect Unknown architecture No Style Listed added September 28, 1989 governing body Private mpsub Waltham MRA refnum 89001574 ref name nris NRISref 2008a ref American Watch ToolCompany is a historic factory building at 169 Elm Street in Waltham, Massachusetts . It was built in 1877 and added to the National Register of Historic Places in 1989. ref name nris References Reflist Registered Historic Places Category Industrial buildings and structures on the National Register of Historic Places in Massachusetts Category Buildings and structures completed in 1877 WalthamMA NRHP stub ... more details
Infobox companycompany name Lewis Machine and ToolCompanycompany logo File Lewis Machine and Tool Company.svg 250px Lewis Machine and Tool logo company type Private company Private foundation 1980 location Milan, Illinois , USA industry Arms industry Defense products Firearm s, weapon s revenue num employees 100 150 homepage http www.LMTDefense.com www.LMTDefense.com Lewis Machine & ToolCompany LMT ref http lmtdefense.com about.php About LMT ref was founded by Karl Lewis in 1980. LMT started its business by providing law enforcement and government agencies with military type weapons and accessories. Today, LMT still provides law enforcement and government agencies with weapons, but they have now also expanded their services to foreign military and commercial retailers. All of LMT s engineering and manufacturing is done in house at the Milan, IL facility. LMT manufactures complete weapon systems such as the M4 AR15 and the M203 grenade launcher . ref http www.thenational.ae article 20090223 PAGETHREE 313906336 1119 The National Military Muscle on Display ref Today, both the US military and the Ministry of Defence United Kingdom United Kingdom s Ministry of Defence utilize many of the products that LMT makes. Notable products infobox weapon name L129A1 image Image L129A1.jpg 204px L129A1 origin United States United States of America type Service rifle is ranged Yes Service history service 2010 Present used by British Armed Forces wars Afghanistan Production history designer design date manufacturer Lewis Machine & Tool unit cost production date number variants General specifications spec label weight convert 9.8 lbs kg cartridge 7.62x51mm NATO cartridge weight caliber barrels convert 16 in mm action rate velocity range 800m max range 900m feed sights Advanced Combat Optical Gunsight ACOG 6x magnification LMT created the Monolithic Rail Platform MRP . ref http www.policemag.com ... for civilian purchase. Government contracts In 2009 Lewis Machine and Tool Co was chosen to supply ... more details
Poyner v. Commissioner 301 F.2d 287 4th Cir.1962 ref cite court litigants Poyner v. Commissioner vol 301 F.2d 287 court 4th Cir. date 1962 url http vlex.com vid poyner mervin pierpont lallah 36686881 ref is a United States tax law case that discusses whether special death benefits paid to an employee s widow are exempt from taxes as a gift under 102 a . It produces five factors as a pertinent test 1 whether the payments were made to the spouse of the deceased shareholder, not to his estate 2 whethor the payor had been under no obligation to make the payments and had, in fact, decided on previous occasions not to make payments to persons qualified 3 whether the company derived benefit of an economic nature from the payments 4 whether the recipient had ever performed any services for the company 5 whether the services of the deceased employee had been fully compensated during his lifetime. Citations Commissionerv. Duberstein , 363 U.S. 278 1960 United States v. Kaiser , 363 U.S. 299 1960 Bogardus v. Commissioner , 302 U.S. 34 1937 Simpson v. United States, 261 F.2d 497 7th Cir. 1958 Bounds v. United States, 262 F.2d 876 4th Cir. 1958 References references Category United States taxation and revenue case law Category United States Court of Appeals for the Fourth Circuit cases Category Legal articles without infoboxes case law stub ... more details
orphan date August 2009 In Washburn v. Commissioner , 5 T.C. 1333 T.C. 1945 , the United States Tax Court attempted to set down some guidelines to determine whether a prize or award qualified as a gift . During 1941, Mrs. Washburn s telephone number was randomly selected and the radio program Pot O Gold called and awarded her 900 for simply answering the phone. The check was delivered within a half hour by a messenger with a telegram that read Herewith draft for nine hundred dollars outright cash gift with our compliments presented by Tum s Pot O Gold program. Congratulations from Tommy Tucker and ourselves. Signed Lewis Howe Company, Makers of Tums. 36 The court concluded that the radio show giveaway prize constituted a nontaxable gift since there was no expectation or effort on the part of the recipient, no subsequent obligation on her part to perform any services or to make any commercial endorsement, no wager made by the recipient, and since the prize transferor had denominated the payment as an outright cash gift. 37 This case became known as the Pot O Gold case. The criteria set forth by the court, including the donor s subjective intention and the lack of effort or obligation on the part of the recipient, became standards by which subsequent courts analyzed the taxability of prizes and awards. 38 Aftermath In response to this and other cases e.g. the Ross Essay Contest case, McDermott v. Commissioner holding that prizes constituted nontaxable gifts, Congress added 74 to the 1954 Code. See S. REP. NO. 1622, 83d Cong., 2d Sess. 13, 178 1954 , reprinted in 1954 U.S. CODE CONG. & AD. NEWS 4621, 4813. Since enactment of 74, courts have rejected the gift theory for prizes and awards. See, e.g., Simmons v. United States, 197 F. Supp. 673 D. Md. 1961 , aff d, 308 F.2d 160 4th Cir. 1962 Hornung v. Commissioner, 47 T.C. 428 1967 . References Washburn v. Commissioner, 5 T.C. 1333 T.C. 1945 DEFAULTSORT Washburn V. Commissioner Category United States Tax Court cases ... more details
Infobox SCOTUS case Litigants Bogardus vCommissioner of Internal Revenue ArgueDate October 18 ArgueYear 1937 DecideDate November 8 DecideYear 1937 FullName Bogardus v. Commissioner of Internal Revenue USVol 302 USPage 34 Citation 58 S.Ct. 61 82 L.Ed. 32, 37 2 USTC P 9534 19 A.F.T.R. 1195 1937 2 C.B. 258 Prior Bogardus vCommissioner of Internal Revenue Reversed 88 F. 2d 646 Subsequent Holding That a distribution of money by a corporation, by a resolution passed by the board of directors and stockholders, to the company s past and present employees who had no ties with the corporation, in recognition of there past service was a non taxable gift which the company received no servers for so it was not compensation for personal services. SCOTUS 1937 1938 Majority Sutherland JoinMajority McReynolds, Butler, Roberts, Hughes Concurrence JoinConcurrence Concurrence2 JoinConcurrence2 Concurrence Dissent JoinConcurrence Dissent Dissent Brandeis JoinDissent Stone, Cardozo, Black Dissent2 JoinDissent2 LawsApplied 26 U.S.C.A. 22 Bogardus v. Commissioner , ussc 302 34 1937 ref cite court litigants Bogardus v. Commissioner vol 302 U.S. 34 court U.S. Supreme Court date November 8, 1937 url http supreme.justia.com us 302 34 case.html ref was a case before the U.S. Supreme Court discussing, under United States tax law , how to distinguish compensation from tax exempt gifts under 102 a . It is notable and thus appears frequently in law school casebook s for the following holdings A payment cannot be both compensation for personal service within the meaning of 22 a of the Revenue Act of 1928 and a gift under b 3 of the same section. Old Colony Trust Co. v. Commissioner , 279 U. S. 716, distinguished ... Empty section date July 2010 See also Commissionerv. Duberstein cites this case References wikisource Bogardus v. Commissioner of Internal Revenue Reflist DEFAULTSORT Bogardus V. Commissioner ... when stockholders of the older company. When the facts and circumstances prove an intent to make a gift ... more details
Infobox SCOTUS case Litigants Commissionerv. Duberstein ArgueDate March 23 ArgueYear 1960 DecideDate June 13 DecideYear 1960 FullName Commissioner of Internal Revenue v. Duberstein, et ux. USVol 363 USPage 278 Citation Prior Subsequent Holding The court upheld the Tax court s ruling with regards to Duberstein but split as to Stanton. SCOTUS 1958 1962 Majority Brennan JoinMajority Concurrence JoinConcurrence Concurrence2 JoinConcurrence2 Concurrence Dissent Frankfurter JoinConcurrence Dissent Harlan Concurrence Dissent2 Black JoinConcurrence Dissent2 Dissent Douglas JoinDissent Dissent2 JoinDissent2 LawsApplied wikisource Commissioner Of Internal Revenue v. Duberstein Commissionerv. Duberstein , ref cite court litigants Commissionerv. Duberstein vol 363 U.S. 278 court date 1960 url http supreme.justia.com us 363 278 case.html ref was a United States Supreme Court case dealing with the exclusion of the value of property acquired by gift from the gross income of an income taxpayer. It is notable and thus appears frequently in law school casebooks for the following holdings When determining ... interested act. Facts The Court was presented with two sets of facts. No. 376, Commissionerv. Duberstein ... Bogardus v. Commissioner , ussc 302 34 1937 . This is a question of fact that must be determined on a case ... generosity. Duberstein at 285 quoting Commissioner of Internal Revenue v. LoBue , 351 U.S. ... cases, volume 363 Bogardus v. Commissioner , ussc 302 34 1937 References references Category United ... Iron & Metal Company. They would often talk on the phone and give each other names of potential customers ... when he filed his tax return, deeming it a gift. The Commissioner asserted a deficiency for the car s value against Duberstein. The Tax court affirmed. No. 506, Stanton v. United States Stanton ... at 285 quoting Robertson v. United States , 343 U.S. 711, 714 1952 . Contrast payments given as an involved and intensely interested act. See Olk v. United States , 536 F.2d 876 9th Cir. 1976 ... more details