Helping Hands (HH) Inc. was incorporated in the current year by Henry and Homer Hand to provide at-home services to senior citizens under the premise that this will help them stay in their homes longer, postponing when they would have to move to a retirement facility. For an annual membership fee of $600, HH will provide "on-call concierge home services," such as household maintenance (window washing, light bulb changing, trash removal, "spring cleaning"), yard maintenance (shrub and tree trimming, leaf blowing, gutter cleaning, snow removal), and setting up and maintaining electronic devices (laptops, printers, TVs and other digital equipment). During the current year, HH collected $360,000 from the sale of 600 annual memberships: MayApril: 100; JuneMay: 100; JulyJune: 100; AugustJuly: 100; SeptemberAugust: 100; OctoberSeptember: 100.

Assuming HH adopted the accrual method of accounting, how much of the annual membership fee income of $360,000, if any, can it defer to the subsequent tax year? Explain and cite the authorities used to arrive at an answer

Research Resources: American Automobile Association, SCt, 61-2 9517; Schlude, SCt, 63-1 9284; Rev. Proc. 71-21, 1971-2 CB 549, modied and superseded by Rev. Proc 2004-34, 2004-22 IRB 991; Artnell, CA-7, 68-2 9593; Code Sec. 451(a)