Frank's Casing Crew & Rental Tools v. Commisioner

P is an "oil field contractor" that sells oil pipes, leases equipment used in oil fields, and provides crews necessary to operate the leased equipment. P's contracts with its customers generally provide that payment is due when P sends the customer an invoice that includes all supporting documentation (i.e., job tickets, equipment tickets, and third party charges). On a number of occasions during the relevant years, P did not invoice a customer until after yearend because it had not yet received a third party's invoice. In those cases, P did not accrue the related income until the year during…