Holding
No. Despite the general rule that requires accrual method taxpayers to include advance payments in the year of receipt, the court carved out a narrow exception for taxpayers such as the petitioners, who are able to prove that services will be performed on fixed dates in one or more subsequent taxable years.
Read more about this topic: Artnell V. Commissioner
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“Things base and vile, holding no quantity,
Love can transpose to form and dignity.
Love looks not with the eyes, but with the mind,
And therefore is winged Cupid painted blind.”
—William Shakespeare (1564–1616)