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the delay alone in these circumstances prevented petitioner’s
income from being clearly reported and reflected.
It may be that use of CCM, per se, does not clearly reflect
income, but it is a method that petitioner was entitled to use
for the period under consideration. Congress, for years after
1986, has practically banned the use of CCM for large contractors
and limited its use to 2-year contracts for certain smaller
contractors who meet specific requirements. In that regard, the
legislative history, coupled with the structure of the post-1986
statute, make it obvious that CCM was not believed to clearly
reflect income in general. That proscription, however, does not
apply to the years before us.
In addition, we are not confronted with the type of “gross
distortion” discussed in Ford Motor Co. v. Commissioner, 102 T.C.
at 100-101. In that case, the taxpayer deducted the total cost
of structured settlements in the year the settlement was reached
and made annual payments over an extended period of years, far in
excess of the period of deferral in this case. Also, as earlier
noted, the difference between petitioner’s reporting and
respondent's determination in terms of the amount of delay
becomes nominal and then disappears as the deliveries approached
the fourth program year of Contract 2034. There was no
difference between respondent's and petitioner’s approaches as
they applied to the 1985 year, other than the question of
severance, because in either case income and deductions would be
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