Ames v. Commissioner
United States Tax Court
112 T.C. 304 (1999)
Relevant factsFree
Ames (plaintiff), a spy for the USSR, was promised illegal payments in 1985 but the USSR didn't actually deposit them in accessible secret locations until 1989-1992, after he handed over stolen documents; the Commissioner (defendant) assessed tax deficiencies for 1989-1992, and Ames argued the income should instead be attributed to 1985 when it was first promised, since he used the cash method of accounting.
IssueFree
Whether, for federal tax purposes, a taxpayer who reports income on the cash method of accounting constructively receives taxable income when he obtains unfettered control over the income.