Chicago White Sox, Inc. handled sales for the Chicago White Sox team. It sold tickets, broadcasting and televising rights, as well as season parking books. As an accrual method taxpayer, Chicago White Sox, Inc. recorded revenues for each game as unearned income until services were actually rendered at each game. On May 31, 1962, Artnell Company (Artnell) (plaintiff) acquired Chicago White Sox, Inc. Artnell filed an income tax return for the taxable year ending May 31, 1962. It excluded the deferred unearned income for future games from its gross income. The Commissioner (defendant) determined a deficiency and required Artnell to include the deferred unearned income as gross income. The Tax Court affirmed the Commissioner’s determination.