[2] The all events test is two-pronged concerning the recognition of income, three-pronged when dealing with deductions.
It is met when (1) the right to income is fixed (recognition of income) or all events have occurred which establish the fact of liability (deduction), and (2) the amount thereof can be determined with reasonable accuracy.
[3] The third prong which is applicable when dealing with an accrual method taxpayer's right to a deduction is (3) economic performance has occurred with respect to the liability.
Taxpayers are put on cash method of accounting in those instances where payment precedes performance or due date of an obligation.
If at the time of sale there was no doubt as to the collectibility of income, doubt that arises subsequent to the time when all events have occurred that fix the right to receipt do not change the fact that all events indeed did occur.