A client calls Lawyer at 4.00 PM, December 31, 2022, saying she has Lawyers fee statement, has made out a check in full payment and, as she is about to leave for Europe, and she will leave the check with a desk clerk at Clients apartment. Lawyer is ill, has no one to send to pick up the check, and he finally arranges to pick it up on January 2, 2023. In what year will Lawyer claim this as income?