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represented closed sales in the year entered. See Arnold v.
Commissioner, a Memorandum Opinion of this Court dated Mar. 17,
1953. We see no reason to infer differently here.
B. Reporting of Gain--Timing of Inclusion
Thus, having decided that petitioners’ contracts for deed
effected a completed sale when executed, we proceed to the
question of when gain from such sales must be included in gross
income. The general rule for the taxable year of inclusion is
set forth in section 451(a): “The amount of any item of gross
income shall be included in the gross income for the taxable year
in which received by the taxpayer, unless, under the method of
accounting used in computing taxable income, such amount is to be
properly accounted for as of a different period.” Regulations
then specify as follows:
Under an accrual method of accounting, income is
includible in gross income when all the events have
occurred which fix the right to receive such income and
the amount thereof can be determined with reasonable
accuracy. * * * Under the cash receipts and
disbursements method of accounting, such an amount is
includible in gross income when actually or
constructively received. * * * [Sec. 1.451-1(a), Income
Tax Regs.]
Taxable income, in turn, generally “shall be computed under the
method of accounting on the basis of which the taxpayer regularly
computes his income in keeping his books”, with the exception
that “if the method used does not clearly reflect income, the
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