Bonner, T.C.C.J.:—This is an appeal from an assessment of income for the appellant's 1986 taxation year. The fiscal year ended on December 30. At issue is the timing of recognition of income earned by the appellant under three contracts, called the first and second CN contracts and the Indonesian contract. The appellant calculated its income for 1986 from the first CN contract on the completed contract basis, that is to say, it disregarded the receipt of instalments of the price payable to it under the contract until all of its obligations were fulfilled.