105 T.C. No. 25 UNITED STATES TAX COURT JOHN M. CAMERON AND CAROLINE D. CAMERON, AND JOHN P. AND TEENA G. BROADAWAY, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 2137-94. Filed November 29, 1995. Ps were shareholders of X, which computed its earnings and profits under the percentage of completion method of accounting. X elected to be taxed as an S corporation and, in a subsequent taxable year, distributed a dividend to Ps. Held, for purposes of measuring the amount of the dividend, X's earnings and profits for its last taxable year as a C corporation must be computed on the basis of year-end estimates of the total costs of its long- term contracts. The estimates may not be revised retroactively to reflect actual costs, and earnings and profits may not be adjusted for subsequent taxable years to which the subchapter S election applied. Edgar J. Tyler, for petitioners. Michael F. O'Donnell, for respondent.Page: 1 2 3 4 5 6 7 8 9 10 11 12 Next
Last modified: May 25, 2011