Petitioners, a husband and wife, were farmers who had contracted to sell an amount of wheat to a purchaser in August 1944. Per the terms of the sale contract, payment for the wheat was not made until January 1945. Petitioners, who used the cash method of accounting, reported gains on the sale of wheat in 1945, when the money was received. The tax commissioner, however, determined that petitioners had an unqualified right to payment as of the delivery of the wheat in August 1944, and should be considered to have realized gains on the sale in the year 1944. Petitioners appealed this decision.
