- 29 - accounting reports. During the performance of Multiyear I, the “Indicated Profit” for each program year, as reflected on the CCPS reports, varied. Under CCM, GENDYN treated Contract 2034 as a single, long- term contract. GENDYN reported all of its taxable income for Contract 2034 in its return for 1987, the year in which the last of the 480 F-16's was delivered. Contract 2038 was negotiated and entered into on April 15, 1982, separate and apart from Contract 2034. Contracts 2038 and 2034 were not related as to the pricing in each contract. Contract 2038 was a firm fixed-price incentive contract under which petitioner was to provide engineering services in connection with the F-16 aircraft. Contract 2038 services were set forth in eight CLIN’s and each CLIN was further separated into numerous individually priced "sub-CLIN" items to, in part, enable petitioner to receive interim progress payments upon completion of sub-CLIN’s. There were business purposes for treating Contract 2038 separately from Contract 2034 and they were separately funded. The subject of Contract 2038 was research, design, and development of new systems for the F-16 aircraft. The new technology was first developed and perfected under Contract 2038 and then integrated into the Contract 2034 aircraft production. Petitioner claimed the income and deductions in connection with Contract 2038 under CCM.Page: Previous 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 Next
Last modified: May 25, 2011