Legal Opinion

General Dynamics Corp. v. Commissioner

United States Tax Court

Decided March 26, 1997No. Docket Nos. 19202-94, 19203-94PublishedCited by 28 opinions

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

  1. United States v. Ron Pair Enterprises, Inc.Supreme Court of the United States · 1989
  2. United States v. CorrellSupreme Court of the United States · 1967
  3. Burnet v. Sanford & Brooks Co.Supreme Court of the United States · 1931
  4. Green v. Bock Laundry MacHine Co.Supreme Court of the United States · 1989
  5. National Muffler Dealers Assn., Inc. v. United StatesSupreme Court of the United States · 1979

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3Cited by28 opinions

  1. UNION CARBIDE CORP. v. COMMISSIONERUnited States Tax Court · 1998
  2. Guardian Industries Corp. v. CommissionerUnited States Tax Court · 2014
  3. Garnett v. Comm'rUnited States Tax Court · 2009
  4. Capital Blue Cross & Subsidiaries v. Comm'rUnited States Tax Court · 2004
  5. Shea Homes, Inc. v. CommissionerUnited States Tax Court · 2014

23 more not listed; retrieve them via the Exa API.

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