108 T.C. No. 9 UNITED STATES TAX COURT GENERAL DYNAMICS CORPORATION AND SUBSIDIARIES, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent GENERAL DYNAMICS FOREIGN SALES CORP., Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket Nos. 19202-94, 19203-94. Filed March 26, 1997. P formed wholly owned corporations (one a DISC, the other an FSC). P computed and reported its Federal income using the completed contract method. P elected, under sec. 1.451-3(d)(5)(iii), Income Tax Regs., to annually deduct certain period costs. In computing the base (combined taxable income) for the statutorily conferred tax benefit to promote exports, P did not account for period costs, which it had elected to deduct annually in prior years. R determined that sec. 994 and/or 925, I.R.C., and the regulations thereunder, required P to include prior years' period costs that are attributable to the gross receipts from foreign exports in computing the base for P's deferral or exemption from income. P manufactured specialized ocean-going vessels for the transport of liquefied natural gas. Sec. 1.993- 3(d)(2)(i)(b), Income Tax Regs., requires that toPage: 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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