cash basis method of accounting was sacrificed for an inconsequential change in the timing of deductions. Under the prorated system the taxpayers could only deduct 1/12 of their rental payment in 1973. But in 1974, and every year until 1992, the taxpayers would be able to deduct both 1/12 of the current payment (for the month of December) and 11/12 for the preceding year's payment that covered the rental period in the current tax year (January–November); thus the taxpayers would be deducting 12/12 of rental payment—an entire year's worth of payments. So there was only a difference between the prorated deduction system and the "one-year rule" for the first and last year of the lease term. Holding The court adopted the "one year rule" and payment in this case was fully deductible in the year of payment. References Samual A. Donaldson, Federal Income Taxation of Individuals: Cases, Problems and Materials (Thompson West 2nd Ed.). Copyright 2007. External links United States taxation and revenue case law United States Court of Appeals for the Ninth Circuit cases 1980 in United States case law