Howard Hughes Properties, Inc. v. CIR

KING, Circuit Judge:

Petitioners-Appellants used the completed contract method of accounting in computing their gains from sales of property under long-term construction contracts. The Internal Revenue Service challenged the method of accounting, arguing that the contracts at issue do not qualify as home construction contracts and that Petitioners-Appellants should therefore have used the percentage of completion method in computing their gains. The Tax Court sided with the Internal Revenue Service. We AFFIRM.

I. FACTUAL AND PROCEDURAL BACKGROUND

Petitioners The Howard Hughes Company, LLC (THHC)…