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deferral of income from advance sales of season tickets and
broadcasting rights until the taxable year in which the games to
which the income was allocable would be played could clearly
reflect income. In so holding, the court distinguished the three
Supreme Court cases cited above, "where the time and extent of
performance of future services were uncertain." "The uncertainty
stressed in those decisions is not present here. The deferred
income was allocable to games which were to be played on a fixed
schedule. Except for rain dates there was certainty." Artnell
Co. v. Commissioner, 400 F.2d at 983-984.
This Court generally has limited Artnell Co. to its facts.
Chesapeake Fin. Corp. v. Commissioner, 78 T.C. 869, 880-881
(1982); T.F.H. Publications, Inc. v. Commissioner, 72 T.C. 623,
644-645 (1979), affd. without published opinion 622 F.2d 579 (3d
Cir. 1980); Standard Television Tube Corp. v. Commissioner, 64
T.C. 238, 242 (1975); Continental Ill. Corp. v. Commissioner,
T.C. Memo. 1989-636, affd. 998 F.2d 513 (7th Cir. 1993); cf.
Collegiate Cap & Gown Co. v. Commissioner, T.C. Memo. 1978-226
(following Artnell Co. in a case appealable to the Seventh
Circuit, under the rule of Golsen v. Commissioner, 54 T.C. 742
(1970), affd. 445 F.2d 985 (10th Cir. 1971). As we stated in
T.F.H. Publications, Inc. v. Commissioner, supra at 644: "Since
Artnell Co. this Court has indicated that it will not follow the
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