The Overlakes Corporation v. Commissioner of Internal Revenue

We affirm the decision of the Tax Court. 41 T.C. 503 (1964). The facts of the case are fully set forth in the Tax Court’s opinion. The petitioner entered into a defense contract in 1951 with the Army Signal Corps Procurement Agency to supply a number of reels of wire as required. The contract contained a provision for redetermination of price “because of the experimental and developmental nature of the work * * * and the great uncertainty as to the cost of performance.” Since petitioner used the accrual method of accounting, the *463amounts for which it billed the contracting agency during 1951…