Tutor-Saliba Corporation, A California Corporation - Page 21




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          1.460-6(c)(1)(ii)(A), Income Tax Regs.  However, the “actual”               
          contract price is to be contrasted with the “estimated” contract            
          price, the latter of which is not governed by the all events                
          test.  Thus, we decline to read the parenthetical language as               
          evidence of congressional intent to apply the all events test to            
          taxpayers’ disputed claims for purposes of computing the                    
          estimated contract price.                                                   
               Furthermore, the language relied on by petitioner is                   
          employed in the context of how the look-back method operates.               
          Taxpayers are required to apply the look-back method to any                 
          amounts that are taken into account after completion of the                 
          contract.  Thus, if income is received and properly accounted for           
          5 or 10 years after completion of the contract, those revenues              
          are discounted back to the year of completion, and the look-back            
          method is applied.  Such application would likely result in                 
          underpayment interest due by the taxpayer if post-completion                
          revenues were not included in the estimated total contract price            
          at the time it was reasonably expected that they would be                   
          received by the taxpayer.                                                   
               In addition, requiring the inclusion of an estimate of                 
          disputed claims in the total contract price as soon as the                  
          taxpayer reasonably expects to receive them will reduce the                 
          likelihood that a taxpayer will have to pay look-back interest.             
          The purpose of the look-back method is to offset the time-value             






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Last modified: May 25, 2011