General Dynamics Corporation and Subsidiaries - Page 32

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          pension and profit-sharing contributions, and costs attributable            
          to strikes, rework labor, scrap, and spoilage.  Sec. 1.451-                 
          3(d)(5)(iii), Income Tax Regs.                                              
               Petitioners' use of the completed contract method of                   
          accounting to report income and deductions for their long-term              
          contracts has not been questioned.  This method of accounting               
          provides an alternative to the annual accrual method of                     
          accounting for long-term contracts for which the ultimate profit            
          or loss is not ascertainable until the contract is completed.               
          See RECO Indus., Inc. v. Commissioner, 83 T.C. 912, 921 (1984).             
          The method allows a taxpayer to account for the entire result of            
          a long-term contract at one time.  Id.  The purpose of the                  
          completed contract method is to match the costs of generating               
          income with the income produced.  In this case, however,                    
          petitioners try to use the completed contract method to avoid the           
          matching of costs with income from export sales for purposes of             
          computing CTI as required by the regulations under sections 994             
          and 925.  As a result, petitioners did not subtract all the costs           
          related to their export sales as defined in section 1.994-                  
          1(c)(6)(iii), Income Tax Regs., from the export income that the             
          expenditures generated.                                                     
               The completed contract method of accounting does not                   
          necessarily conflict with requiring taxpayers to account for all            
          related period costs in determining CTI.  The completed contract            
          method is an accounting method that allocates to a particular               




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