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rationale of that case unless the facts present a certainty, of
performance or fixed dates, such as was presented in Artnell Co."
The cases at hand are distinguishable from Artnell Co. on
their facts. First, the evidence does not establish that the
Dealerships incurred costs for administration of the PLRF
arrangement according to a fixed schedule. We concluded above
that, in the absence of mileage information, the Dealerships
could reasonably estimate their administrative costs in
accordance with the passage of time. But the amount of mileage
driven under a contract would be ascertainable for any year in
which a mechanical breakdown or cancellation occurred, and might
control the determination of costs incurred for that year. Thus,
the proper schedule for accrual of these costs remained at all
times contingent upon wholly unpredictable variables. Cf. T.F.H.
Publications, Inc. v. Commissioner, supra; Standard Television
Tube Co. v. Commissioner, supra. Second, as petitioners
themselves argued with respect to the reserve deposits issue, the
Dealerships' performance is not certain, because the purchaser
retains the right to cancel. If the Dealerships were permitted
to defer income until the period when they are allowed offsetting
deductions for Fees and Premiums, they might never report the
income. Cf. Continental Ill. Corp. v. Commissioner, supra. It
was not an abuse of discretion for respondent to refuse to permit
the Dealerships to match their income with their expenses.
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