Rev. Rul. 59-142

Prepaid subscription income received by a taxpayer in taxable years beginning before January 1, 1958, is includible in gross income for the taxable year in which received unless, under the authority of I.T. 3369, C.B. 1940-1, 46, the taxpayer was permitted to continue to use the method of reporting an aliquot part of subscription income for each year of the subscription period, because such method had consistently been followed by the taxpayer over a period of years prior to publication of I.T. 3369. Section 455 of the Internal Revenue Code of 1954, relating to the reporting of prepaid subscription income for Federal income tax purposes, which was added to the Internal Revenue Code by section 28 of the Technical Amendments Act of 1958 (Public Law 85-866), enacted September 2, 1958, C.B. 1958-3, 254, is effective only for taxable years beginning after December 31, 1957, and has no effect on the method of reporting prepaid subscription income by taxpayers for taxable beginning before January 1, 1958.

¹ Based on Technical Information Release 106, dated October 13, 1958.