- 14 - phrase “estimated contract price”.5 This language indicates that Congress was aware of the fact that taxpayers were being required to estimate when using the percentage of completion method in accounting for long-term contracts. The fact that section 460(b)(2)(A) requires a taxpayer to substitute “actual contract price and costs” for “estimated contract price and costs” when applying the look-back method at the contract’s completion underscores the fact that the total contract price used in the percentage of completion method calculation is an estimate of the total contract price and is likely to change during the performance of the contract. This conceptual underpinning is the antithesis of the all events test.6 The term “estimated” does not necessarily include, as respondent contends, revenues from disputed claims. The term “estimate,” however, does not preclude the possibility that Congress intended that disputed claims be included. In any 5 The parties do not dispute the definition of the term “estimated”. According to the dictionary, “estimate” means to judge tentatively or approximately the value, worth or significance of; to determine roughly the size, extent, or nature of; or to produce a statement of the approximate cost of. See Merriam-Webster’s Tenth Collegiate Dictionary 397 (1997). 6 Furthermore, in a number of tax accounting cases, the Supreme Court has decided that estimates of anticipated expenses are not accruable as deductions under the all events test. See United States v. General Dynamics Corp., 481 U.S. 239, 243-244 (1987). The repeated use of the word “estimated” indicates that standard principles of accrual accounting, including the all events test, are not determinative.Page: Previous 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 Next
Last modified: May 25, 2011