- 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
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