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A cash basis taxpayer cannot be deemed to have realized income at the time a promise to pay in the future. See Bedell v. Commissioner, 30 Fed. (2d) 622, wherein the court said: While, therefore, we do not think that the case is like a promise to pay in the future for a title which passes at the time of contract, we would not be understood as holding by implication that even in that case the profit is to be reckoned as of the time of sale. If a company sells out its plant for a negotiable bond issue payable in the future, the profit may be determined by the present market value of the bonds. But if land or a chattel is sold, and title passes merely upon a promise to pay money at some future date, to speak of the promise as property exchanged for the title appears to us a strained use of language, when calculating profits under the income tax. * * * it is absurd to speak of a promise to pay in the future as having a 'market value,' fair or unfair. * * * 

The doctrine that a cash ...

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