Tutor-Saliba Corp. v. Commissioner
United States Tax Court
Under the Tax Reform Act of 1986, Pub. L. 99-514, 100 Stat. 2085, Congress changed the reporting method for long-term contracts from the completed contract method to the percentage of completion method. Under the percentage of completion method of sec. 460(b), I.R.C., taxpayers are required to include in income during the years of construction a portion of the "estimated contract price."
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Under the Tax Reform Act of 1986, Pub. L. 99-514, 100 Stat. 2085, Congress changed the reporting method for long-term contracts from the completed contract method to the percentage of completion method. Under the percentage of completion method of sec. 460(b), I.R.C., taxpayers are required to include in income during the years of construction a portion of the "estimated contract price." In promulgating sec. 1.460- 6(c)(2)(vi), Income Tax Regs., the Secretary concluded that the term "estimated contract price" includes amounts related to contingent rights and obligations, regardless of whether…
1Opinion of the Court
Gerber, Judge:
Pursuant to Rule 121,1 this matter is before the Court on petitioner’s motion for partial summary-judgment. The parties seek to determine, as a matter of law, whether section 1.460-6(c)(2)(vi)(A) and (B), Income Tax Regs., is invalid to the extent it contains no requirement that disputed long-term contract claims meet the “all events test” to be includable in the estimated contract price within the context of section 460.
Summary judgment may be granted if the pleadings and other materials demonstrate that no genuine issue exists as to any material fact and that a decision may be…
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