- 4 - produced and/or provided other miscellaneous goods and services. GENDYN was also involved in other business activities, including the design, engineering, and manufacture of commercial aircraft; the mining of coal, lime, limestone, sand, and gravel; the manufacture and sale of ready-mix concrete, concrete pipe, and other building products; production of commercial aircraft subassemblies; the design, engineering, and manufacture of commercial space launch vehicles; and shipbuilding. GENDYN, for the taxable years 1977 through 1986 (concerning the contracts under consideration), used the completed contract method (CCM) for reporting Federal income tax and the percentage of completion method for its financial accounting purposes. In 1976, GENDYN applied to respondent for permission to change its accounting method to the completed contract method for reporting income from its long-term contracts for all of its divisions. GENDYN advised respondent that CCM would not be used for financial reporting purposes. In 1977, respondent approved GENDYN's use of CCM for all its long-term contracts. During 1980, an Internal Revenue Service examining agent challenged GENDYN's use of CCM. The agent submitted a request for a technical advice memorandum to respondent's National Office. The agent argued, inter alia, that GENDYN's use of CCM resulted in the unreasonable deferral of income. In a technical advice memorandum released in 1983, the National Office rejectedPage: Previous 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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