In the case of Stough v. Commissioner, 144 TC No. 16, the taxpayer was looking to argue that a payment of $1 million received during the year was either not rental income (being a reimbursement of construction costs) or, if it was rental income, it should have been reported over the entire 10 year life of the lease.  And if neither of those were true, at least the taxpayer should be able to avoid a substantial understatement penalty because the taxpayer had relied upon an experienced CPA to prepare the return in question.