Amend v. Commissioner
United States Tax Court
13 T.C. 178 (1959)
Relevant factsFree
Amend (plaintiff), a cash-basis wheat farmer, delivered wheat to a buyer in August 1944 under a contract specifying payment wouldn't be due until January 1945; the buyer paid on schedule in 1945, and Amend reported the income that year, but the Commissioner (defendant) argued Amend constructively received the payment in 1944 because he had already fully performed.
IssueFree
Whether, for federal tax purposes, a cash-basis taxpayer constructively receives income at the time a promise to pay in the future is made.