In 1944, J. D. Amend (plaintiff), a wheat farmer, entered into an arm’s-length contract to sell wheat to the Burrus Mill & Elevator Company (Burrus), with payment due in January 1945. Amend delivered the wheat to Burrus in August 1944. Burrus paid Amend for the wheat in January 1945 per the terms of their contract. Amend operated his business on the cash-basis method of accounting. Accordingly, Amend accounted for Burrus’s payment as gross income in 1945, the year Amend received the payment. The tax commissioner (commissioner) (defendant) issued a deficiency notice for the 1944 tax year, holding that Amend had constructive receipt of Burrus’s payment in 1944 and was obligated to pay taxes on the payment as income in that year. Amend petitioned the United States Tax Court for review of the commissioner’s deficiency notice.