Howard Hughes Co. v. Commissioner, No. 14-60915 (5th Cir. 2015)
Annotate this CasePetitioners are subsidiaries of the Howard Hughes Corp., an entity involved in selling and developing commercial and residential real estate. Petitioners used the completed contract method of accounting in computing their gains from sales of property under long-term construction contracts. The IRS challenged the method and the Tax Court sided with the IRS. At issue was whether petitioners' contracts were “home construction contracts” within the meaning of I.R.C. 460(e)(6)(A), thereby making petitioners eligible to use the completed contract method of accounting. The court concluded that petitioners' construction contracts do not fall within the meaning of subsection (i) of section 460(e)(6)(A) or subsection (ii) of section 460(e)(6)(A). Because petitioners' contracts are not "home construction contracts," within the meaning of the statute, the court affirmed the Tax Court's judgment.
The court issued a subsequent related opinion or order on October 30, 2015.
The court issued a subsequent related opinion or order on December 7, 2015.
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