- 3 -
contract was a 48-month contract (multiyear) for delivery of 480
aircraft. Respondent determined that 2034 should be treated as
four separate agreements, each for the delivery of 120 aircraft.
With respect to Government contract numbered F33657-82-C-
2038 (Contract 2038 or 2038), GENDYN allocated the income and
expenses to multiyear Contract 2034 so that Contract 2038 was
reported under the completed contract method for Federal income
tax purposes. Respondent determined that the income and expenses
from 2038 were not part of the completed contract reporting for
Contract 2034. Consequently, respondent also determined that
Contract 2038 should have been separately accounted for under the
accrual method of accounting.
FINDINGS OF FACT3
GENDYN was incorporated on February 21, 1952, and, at all
relevant times, was the common parent of a group of corporations
that filed consolidated corporate Federal income tax returns. At
the time the petitions were filed in these cases, GENDYN's and
GENDYN/FOREIGN's principal places of business were in Falls
Church, Virginia. GENDYN engineered, developed, and manufactured
various products for the U.S. Government and, to a lesser extent,
foreign Governments, including military aircraft, missiles, gun
systems, space systems, tanks, submarines, and electronics, and
3 The parties’ stipulation of facts and exhibits are
incorporated by this reference.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011