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fixes petitioner’s right to receive the commission income. The
functions that remain to be performed by petitioner after the
trade date are of a ministerial nature to effectuate the
mechanics of the transfer and confirm the trade executed.
Although failure to perform these functions may ultimately divest
petitioner of its right to the commission income, we think that
these functions are conditions subsequent and, therefore, do not
preclude accrual of commission income on the trade date.
Nor does the possibility that an executed trade may not
settle due to cancellation of an entire public offering make
petitioner’s right to the commission income too indefinite or
contingent for accrual. See Brown v. Helvering, 291 U.S. 193,
199-200 (1934) (holding that overriding commissions received by a
general agent for policies written must be accrued even though
there was a contingent liability to return a portion of the
commission in the event the policy was canceled); Georgia School-
Book Depository, Inc. v. Commissioner, 1 T.C. 463, 468-470 (1943)
(holding that a book broker that represented publishers in sales
of school books to the State of Georgia must accrue commission
income, despite the fact that the State was obligated to pay for
the books only out of a particular fund, and, during the years in
issue, the fund was insufficient to pay for the books in full).
The possibility that a trade might not finally be settled is, if
anything, a condition subsequent to the execution of the trade,
which was the event that fixed petitioner's right to the
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