- 21 - always by the end of the next succeeding taxable year. Petitioner reported the annual fees in income on a pro rata basis over a 12-month period. Since the full range of services, including contingent services performed on the cardholder's demand, would be available over the 12-month period for which the fee was paid, it would be "not unreasonable" to anticipate that a substantially ratable portion would be performed or available to be performed in whatever portion of the 1-year period remained at the end of any given taxable year. The cardholder pays for services to be available at all times over the 1-year period of the agreement, whether or not the particular cardholder avails himself of those services. Petitioner's pro rata inclusion of income over the 12-month period is reasonable and within the purview of Rev. Proc. 71-21. We think the revenue procedure does not require the type of matching of income and expense that respondent insists upon. The revenue procedure permits accrual basis taxpayers to defer the inclusion in gross income of payments received (or due and payable) in one year for services to be performed by the end of the next succeeding taxable year. Petitioner's method does that. The purpose of the revenue procedure was to reconcile tax and financial accounting treatment of such payments without permitting extended deferral beyond the end of the next succeeding taxable year. Petitioner's method is that required for financial and regulatory accounting purposes; hence thePage: Previous 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 Next
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