References in periodicals archive ?
Publication 538 (12/2016), Accounting Periods and Methods, https://www.
See also section 448 of the Internal Revenue Code; Notice 2001-76 in Internal Revenue Bulletin 2001-52; and IRS Publication 538, Accounting Periods and Methods.
Even the IRS seems to treat it both ways: In Publication 538, Accounting Periods and Methods, it seems to view economic performance as separate from the all-events test, whereas in CCA 200834019 it treats economic performance as a third prong in the all-events test.