John M. Cameron and Caroline D. Cameron, and John P. and Teena G. Broadaway - Page 5

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          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.                                          






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