Tutor-Saliba Corporation, A California Corporation - Page 16




                                       - 16 -                                         
          projected.  Thus, Congress provided for a “look-back” to account            
          for variances between the estimated and the actual figures.                 
               Although there is no specific support in the legislative               
          history for respondent’s position, use of the terms “expected”              
          and “anticipated” lends support to respondent’s position and is             
          helpful to our consideration.  The House report described the               
          intended operation of the percentage of completion method as                
          follows:                                                                    
               Income from all long-term contracts must be reported                   
               under the percentage of completion method based on the                 
               expected costs rather than physical completion.  Thus,                 
               the amount of gross income from a long-term contract                   
               recognized in a particular taxable year generally is                   
               that proportion of the expected contract price that the                
               amount of costs incurred through the end of the taxable                
               year bears to the total expected costs, reduced by                     
               amounts of gross contract price that were included in                  
               gross income in previous taxable years.  [H. Rept. 99-                 
               426 (1986), 1986-3 C.B. (Vol. 2) 630; emphasis added.]                 
               In describing the operation of the look-back method, the               
          Staff of the Joint Committee on Taxation added:                             
               In the taxable year in which the contract is                           
               completed, a determination is made whether the taxes                   
               paid with respect to the contract in each year of the                  
               contract were more or less than the amount that would                  
               have been paid if the actual gross contract price and                  
               the actual total contract costs, rather than the                       
               anticipated contract price and costs, had been used to                 
               compute gross income. [Staff of Joint Comm. on                         
               Taxation, General Explanation of the Tax Reform Act of                 
               1986, at 528 (J. Comm. Print 1987); emphasis added.]                   
               * * *                                                                  










Page:  Previous  5  6  7  8  9  10  11  12  13  14  15  16  17  18  19  20  21  22  23  24  Next

Last modified: May 25, 2011