Professor White operates a popular CPA exam review course as

Professor White operates a popular CPA exam review course as a sole proprietor. He charges $2,000 tuition to each student, and he guarantees a full refund of the tuition if the student passes an in-course exam but does not pass the actual CPA exam on the first try. White is bold enough to do this because the first-time-pass rate for his students is more than 80 percent. He collected $150,000 tuition for his fall 2017 review section, but he reported the gross receipts on his 2018 Form 1040 because the grades for those taking the fall review are not released until February 2018. Thus, White asserted that he had no constructive receipt of the tuition until February 2018. Is this treatment correct?