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petitioner and because of substantial doubt, as of February 28,
1989, as to collectibility of any further payments from Clinch
River. Petitioner also makes other alternative arguments.
OPINION
Generally, under section 451(a) and the regulations
thereunder, an accrual basis taxpayer is required to accrue for
each year income where, during that year, all events have
occurred that fix the taxpayer's right to receive the income and
where the amount can be determined with reasonable accuracy.
Secs. 1.446-1(c)(1)(ii), 1.451-1(a), Income Tax Regs. The time
when income accrues is largely a question of fact. San Francisco
Stevedoring Co. v. Commissioner, 8 T.C. 222, 226 (1947).
Income that satisfies the all-events test of the accrual
method of accounting is generally accruable even though later
events may postpone, even until a subsequent year, actual payment
and receipt of the amount fixed and due. Harmont Plaza, Inc. v.
Commissioner, 64 T.C. 632, 648, 649 (1975), affd. 549 F.2d 414
(6th Cir. 1977); Georgia School-Book Depository, Inc. v.
Commissioner, 1 T.C. 463, 468 (1943).
A limited exception to the above general rule regarding the
accrual of income may apply when, in the same year that a
taxpayer's right to income arises, collection and receipt of the
income become sufficiently doubtful or when it becomes reasonably
certain that the income will not be collected. Clifton
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