1982),[1] was a case decided before the United States Court of Appeals for the Ninth Circuit that decided the question of when the right to receive income represented by "markers", or gambling credit lines, become "fixed" for tax purposes based on the "all events" test.

On its 1967 tax return, the casino, an accrual basis taxpayer, excluded $676,432.00 of receivables attributable to uncollected loans from "markers" issued.

"[2] The casino argued that the right to receive income from the "markers" was not "fixed" because Nevada does not recognize a legal obligation for customers to pay gambling debts of this sort.

Therefore, the court held that the casino's right to the income was "fixed" for accrual purposes and that the "markers" must be accrued when issued.

This prevents casinos from being able to defer income into later taxable years simply by running much of their play on credit lines.