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HOWARD HUGHES COMPANY, L.L.C. v. C.I.R.

No. 14-60915.

805 F.3d 175 (2015)

HOWARD HUGHES COMPANY, L.L.C., formerly known as Howard Hughes Corporation and Subsidiaries, Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee. Howard Hughes Properties, Incorporated, Petitioner-Appellant, v. Commissioner of Internal Revenue, Respondent-Appellee.

United States Court of Appeals, Fifth Circuit.

October 27, 2015.

Attorney(s) appearing for the Case

Kevin Lee Kenworthy, Esq . (argued), Steven R. Dixon , Stephen F. Gertzman , Alan I. Horowitz , Sat Nam Singh Khalsa, Miller & Chevalier Chartered, Washington, DC, for Petitioner-Appellant.

Andrew M. Weiner (argued), Kathryn Keneally , Teresa Ellen McLaughlin , U.S. Department of Justice, Washington, DC, Ronald S. Collins, Jr.   William J. Wilkins , Internal Revenue Service, Washington, DC, for Respondent-Appellee.

Before: KING, DENNIS, and OWEN, Circuit Judges.

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...

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