Guy F. Atkinson Co. v. Commissioner
United States Tax Court
A member of petitioners' consolidated return group was a member of a joint venture which was engaged in the construction of a water tunnel. The venture, which employed the completed contract method for reporting income and expenses, unilaterally withdrew from the project without finishing it in 1975 after suffering extensive losses.
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A member of petitioners' consolidated return group was a member of a joint venture which was engaged in the construction of a water tunnel. The venture, which employed the completed contract method for reporting income and expenses, unilaterally withdrew from the project without finishing it in 1975 after suffering extensive losses. Held, 1975 was not the year of contract completion, and petitioners may not deduct their distributive share of the venture's losses from constructing the tunnel in that year. Another member of petitioners' consolidated return group was engaged in the construction…
1Opinion of the Court
Guy F. Atkinson Company of California and Subsidiaries, Petitioners v. Commissioner of Internal Revenue, Respondent
Guy F. Atkinson Co. v. Commissioner
Docket No. 8750-81
United States Tax Court
82 T.C. 275; 1984 U.S. Tax Ct. LEXIS 105; 82 T.C. No. 24;
February 16, 1984, Filed
Decision will be entered under Rule 155.
A member of petitioners' consolidated return group was a member of a joint venture which was engaged in the construction of a water tunnel. The venture, which employed the completed contract method for reporting income and expenses, unilaterally withdrew from the project without…
2Cases cited30 opinions
- Manhattan General Equipment Co. v. Commissioner of Internal RevenueSupreme Court of the United States · 1936
- Samuel Pollack and Annie Pollack v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1968
- Pollack v. CommissionerUnited States Tax Court · 1966
- National Contracting Co. v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1939
- Estate of Scofield v. CommissionerUnited States Tax Court · 1956
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