Tampa Bay Devil Rays, Limited (plaintiff) owned the Tampa Bay Devil Rays baseball team. The Devil Rays used the accrual method of accounting. The Devil Rays received deposits and other advance payments from spectators for tickets to games that were to take place the following year. The Devil Rays did not report this income in the year in which they received the funds. Rather, the Devil Rays reported the income in the following year, the year in which the games were actually played. The Internal Revenue Service (IRS) (defendant) determined that the Devil Rays should have reported the income in the year in which they received the funds. The Devil Rays appealed to the United States Tax Court.