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Held: Sec. 1.460-6(c)(2)(vi), Income Tax Regs.,
is a reasonable interpretation of the statute, comports
with the legislative history, and, accordingly, is
valid.
Marilyn Barrett, for petitioner.
Steven M. Roth and Jonathan H. Sloat, for respondent.
OPINION
GERBER, Judge: Pursuant to Rule 121,1 this matter is before
the Court on petitioner’s motion for partial summary judgment.
The parties seek to determine, as a matter of law, whether
section 1.460-6(c)(2)(vi)(A) and (B), Income Tax Regs., is
invalid to the extent it contains no requirement that disputed
long-term contract claims meet the “all events test” to be
includable in the estimated contract price within the context of
section 460.
Summary judgment may be granted if the pleadings and other
materials demonstrate that no genuine issue exists as to any
material fact and that a decision may be entered as a matter of
law. See Rule 121(b); Sundstrand Corp. v. Commissioner, 98 T.C.
518, 520 (1992), affd. 17 F.3d 965 (7th Cir. 1994). There is no
genuine issue as to any material fact with respect to the
1 Unless otherwise indicated, all Rule references are to
the Tax Court Rules of Practice and Procedure, and all section
references are to the Internal Revenue Code in effect for the
taxable years at issue.
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Last modified: May 25, 2011