General Dynamics Corp. v. Commissioner
United States Tax Court
P formed wholly owned corporations (one a DISC, the other an FSC). P computed and reported its Federal income using the completed contract method. P elected, under sec. 1.451-3(d) (5) (iii), Income Tax Regs., to annually deduct certain period costs. In computing the base (combined taxable income) for the statutorily conferred tax benefit to promote exports, P did not account for period costs, which it had elected to deduct annually in prior years.
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P formed wholly owned corporations (one a DISC, the other an FSC). P computed and reported its Federal income using the completed contract method. P elected, under sec. 1.451-3(d) (5) (iii), Income Tax Regs., to annually deduct certain period costs. In computing the base (combined taxable income) for the statutorily conferred tax benefit to promote exports, P did not account for period costs, which it had elected to deduct annually in prior years. R determined that sec. 994 and/or 925, I.R.C., and the regulations thereunder, required P to include prior years' period costs that are…
1Opinion of the Court
Gerber, Judge:
General Dynamics Corp. and its consolidated subsidiaries (gendyn) (docket No. 19202-94) and its foreign sales corporation, General Dynamics Foreign Sales Corp. (gendyn/fsc) (docket No. 19203-94), are petitioners in these consolidated cases. Respondent determined corporate income tax deficiencies for GENDYN in the amounts of $26,118,976 and $291,218,973 for its 1985 and 1986 taxable years, respectively. With respect to gendyn/fsc, respondent determined a $586,533 corporate income tax deficiency for its 1986 taxable year. Although these cases are consolidated and related, for…
2Cases cited25 opinions
- United States v. Ron Pair Enterprises, Inc.Supreme Court of the United States · 1989
- United States v. CorrellSupreme Court of the United States · 1967
- Burnet v. Sanford & Brooks Co.Supreme Court of the United States · 1931
- Green v. Bock Laundry MacHine Co.Supreme Court of the United States · 1989
- National Muffler Dealers Assn., Inc. v. United StatesSupreme Court of the United States · 1979
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