Tutor-Saliba Corporation, A California Corporation - Page 8




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          L. 101-239, 103 Stat. 2106, 100 percent of contract items for               
          long-term contracts entered into on or after July 11, 1989, had             
          to be reported under the percentage of completion method.                   
               Under the percentage of completion method of accounting,               
          income from the contract must be reported over the life of the              
          contract, and expenses must be deducted in the year incurred.               
          The reportable income for each year is calculated as follows:               
          the total contract costs incurred through the end of the tax year           
          are divided by the total estimated contract costs, and then                 
          multiplied by the total contract price; the product of this                 
          multiplication is reduced by gross income from the contract                 
          reported for prior years.  See sec. 460; Cameron v. Commissioner,           
          105 T.C. 380 (1995), affd. sub nom. Broadway v. Commissioner, 111           
          F.3d 593 (6th Cir. 1997).                                                   
               Under section 460(b), a taxpayer is required to apply the              
          “look-back method” upon a contract’s completion (and possibly               
          again after a postcompletion event) to compensate the prejudiced            
          party (taxpayer or Government) for a taxpayer’s overestimation or           
          underestimation in applying the percentage of the completion                
          method.  Under this method, the taxpayer recomputes its income              
          tax (theoretically--since, in reality, taxpayers do not amend any           
          tax returns) for each year of the contract using the actual                 
          contract price and costs instead of estimates.  Based on this               
          reconciliation, the taxpayer pays interest to the Government on             






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