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Artnell Co. v. Commissioner, 400 F.2d 981 (7th Cir. 1968),
acq. 1968-2 C.B. 1, revg. and remanding 48 T.C. 411 (1967),
involved facts very similar to those involved herein. Therein
the Court of Appeals for the Seventh Circuit concluded that funds
received by the Chicago White Sox, Inc. (White Sox) on advance
ticket sales relating to major league baseball games to be played
in a following year may appropriately be deferred and included in
the White Sox’s income in the year when the games were to be
played if that deferral would clearly reflect the White Sox’s
income. Id. at 985. The Court of Appeals for the Seventh
Circuit remanded the case to us for analysis of whether the White
Sox’s deferral of reporting the funds as income until the year in
which the games were played would clearly reflect income. Id. at
985-986.
On remand in Artnell Co. v. Commissioner, T.C. Memo. 1970-
85, we concluded that the White Sox’s method of accounting for
the funds clearly reflected income because deferral of the funds
until the year in which the games were played more clearly than
respondent’s method matched the income with the White Sox’s major
expenses that were incurred in the year when the games were
played.
In subsequent opinions, we have stated that Artnell Co. will
be limited to its facts. See Johnson v. Commissioner, 108 T.C.
448, 492 (1997), affd. in part, revd. in part, and remanded on
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