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gamma corporation a calendar year accrual basis taxpayer operates department stores 4274862

Gamma Corporation, a calendar-year accrual-basis taxpayer, operates department stores. Alpha Corporation and Beta Corporation are wholly-owned domestic subsidiaries of Gamma Corporation and file a consolidated federal tax return under Gamma Corporation’s consolidated group. Gamma, Alpha, and Beta enter into a gift card service agreement under which Gamma is primarily liable for the value of the gift cards until redemption while Alpha and Beta are obligated to accept the gift cards as payment for goods and services. Gamma issues the gift cards and reimburses Alpha and Beta for the sale price of the goods and services purchased with the gift cards. The group recognizes revenue in its applicable financial statement when the gift cards are redeemed. In year 1, Gamma Corporation makes $2 million in gift card sales. Gamma tracks redemptions of gift cards electronically and determined that $1,800,000 was redeemed in year 1. How much revenue does Gamma Corporation recognize from the gift card sales for tax purposes and in which year(s)?

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