The court of claims sustained the Commissioner, finding that the national automobile club had failed to apply members' prepaid dues as taxable income in the calendar year of their actual receipt.

It was held that the Commissioner of Internal Revenue did not abuse his discretion in determining that the prepaid dues were taxable as income in the year in which they were actually received and in rejecting the taxpayer's method of accounting.

[2] In particular, petitioner's practice of accounting for expected future service expenses in advance could have been found purely artificial by the Commissioner.

Furthermore, Congress had specifically authorized petitioner's desired method of accounting only in the instance of prepaid subscription income and had refused to enlarge 26 U.S.C.

Moreover, Congress had refused to enlarge the use of petitioner's method of accounting beyond the area of prepaid subscription income in the field of publishing.