Toward the end of 1974, Robert Carter (plaintiff) took a job for the City of New York. Payroll issues made the city unable to promptly pay Carter. On January 3, 1975, the city paid Carter for four weeks of services rendered in 1974. Carter had been unemployed for most of 1974, and if he had received the four weeks’ pay in 1974, he would have owed no additional taxes. Carter, a cash-basis taxpayer, reported the four weeks’ income on his 1974 tax return. The Internal Revenue Service (IRS) (defendant) assessed a deficiency against Carter, determining that the income should have been reported on his 1975 return. Carter appealed, arguing that he constructively received the income in 1974.