- 13 - The issues under consideration arise in connection with GENDYN and its foreign sales corporations. One issue concerns the manner in which petitioners compute the amount of commission income that may be deferred or excluded under the foreign sales corporation statutes and regulations. That issue is one of first impression, involving the interpretation of certain statutes and regulations. The other issue concerns whether either of two ships is export property under section 993(c)(1) so as to enable petitioners to include it in the computation of commission income under the foreign sales corporation statutes and regulations. We first consider the former issue. I. Petitioners’ Treatment of Period Costs in Computing Combined Taxable Income Petitioners were on the completed contract method of accounting for long-term contracts for Federal income tax purposes. In the process of computing corporate Federal income tax under the completed contract method, GENDYN, under section 1.451-3(d)(5)(iii), Income Tax Regs., elected to expense rather than capitalize certain period expenses. Normally, under the completed contract method, the income and expenses connected with long-term contracts are not reported or claimed until the completion of the contract. In computing the allowable amount of deferral or exclusion of DISC or FSC commission income, petitioners did not include the period costs that were deducted in prior years' domestic FederalPage: Previous 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 Next
Last modified: May 25, 2011