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petitioner had completed its performance with respect to the
sales and services. The parties do not dispute the amount of
income earned by petitioner for these goods and services. We
conclude that respondent committed no abuse of discretion in
determining that the all events test had been met. Petitioner
must accrue income from the goods and services in the taxable
year in which performance occurs, and it cannot wait until the
year in which it invoices its customer. Although petitioner may
not have physically possessed all of the documentation necessary
to invoice its customers for the sales and services in the year
of performance, petitioner's preparation and sending of the
invoices were ministerial acts that did not postpone accrual of
the income otherwise earned. See Continental Tie & Lumber Co. v.
United States, 286 U.S. 290 (1932); Dally v. Commissioner, 227
F.2d 724 (9th Cir. 1955), affg. 20 T.C. 894 (1953); Frost Lumber
Indus. v. Commissioner, 128 F.2d 693 (5th Cir. 1942), revg. 44
B.T.A. 1249 (1941); Orange & Rockland Utils., Inc. v.
Commissioner, 86 T.C. 199, 214 (1986). For purposes of the
all-events test, completion of petitioner's performance on the
contracts fixed its right to receive payment for the goods and
services, regardless of petitioner's invoicing practice.2
2 While we have previously upheld deferred billing practices
of certain taxpayers, those taxpayers generally operated in a
heavily regulated industry or were able to establish wide
acceptance within their industry of such an accounting practice.
See, e.g., Orange & Rockland Utils., Inc. v. Commissioner,
86 T.C. 199 (1986); Public Serv. Co. of New Hampshire v.
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