- 5 - years ended after October 31, 1988, then the accumulated earnings and profits and resulting deficiencies for the 1989 taxable year are: E&P Broadaways Camerons ($21,851.09) $2,323 $3,109 Our task is to select the one alternative, if any, that is in accordance with the governing law. Discussion It is undisputed that Company was required to use the percentage of completion method for purposes of computing its earnings and profits. Sec. 312(n)(6). The first issue is how to perform this computation. Under section 460 as enacted by the Tax Reform Act of 1986, Pub. L. 99-514, sec. 804, 100 Stat. 2358, gross income from a long-term contract is taken into account as the work progresses. The amount of gross income from a long-term contract that is accrued for each taxable year is that proportion of the expected total contract income that the amount of costs incurred through the end of the taxable year bears to the total expected costs, reduced by cumulative amounts of contract income that were reported for previous taxable years. Sec. 460(b); H. Rept. 99-426, at 630 (1986), 1986-3 C.B. (Vol. 2) 630; see also Kollsman Instrument Corp. v. Commissioner, T.C. Memo. 1986-66, affd. 870 F.2d 89 (2d Cir. 1989); Berger Engg. Co. v. Commissioner, T.C. Memo. 1961-292.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
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