Your client is a resident of Florida. He has asked you to research whether he must recognize some of his receipts as income. Your research resulted in locating the following authority:
* Revenue Ruling that speaks directly to the issue and requires income recognition.
* U.S. District Court case in Florida (with jurisdiction over your client) that directly addresses the issue and concludes the income may be excluded from taxable income.
* Ninth Circuit Court of Appeals case that, although the facts are slightly different, concludes the income must be included.
What will you advise the client?