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Adrian is a salesperson who represents several wholesale companies. On January 2, 2018, she receives by mail a commission check from Ace Distributors in the

Adrian is a salesperson who represents several wholesale companies. On January 2, 2018, she receives by mail a commission check from Ace Distributors in the amount of $10,000 and dated December 30, 2017. Adrian is concerned about the year in which the $10,000 is taxable. Although the check is dated 2017, she contends that it would have been unreasonable for her to drive the 50 miles to the Ace offices on a holiday to collect the check. Further, Adrian maintains that even if she had made the trip to collect the check, by the time she returned home, her bank would have closed and she could not have received credit for the check until after the first of the year. Adrian would like you to determine whether she should include the $10,000 on her 2017 or 2018 tax return. 61; Reg. 1.451-1; Murphy v. U.S., 71 AFTR 2d 93-1862 (CA9, 1993); Kahler, 18 T.C. 31 (1942); Zahirdueen Premji, et ux. v. Commissioner, TC Memo 1996-304.

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