Ernst is an accountant. Until 30 June 2019, he was in sole practice and employed three accountants. Ernst always recorded his practice's income on a cash basis. On 1 July 2019, Ernst formed a partnership with two of his former employees. The partnership accounted for its income on an accruals basis. In June 2020, Ernst received $11,000 in outstanding fees relating to services that he had provided to one of his client's during 2018. Can Ernst rely on Henderson v FC of 170 ATC 4016 to argue that he should not be assessed on this amount because he changed his basis of accounting