The taxpayer qualified for the disability tax credit (DTC) retroactively for a number of years. Some of it was prior to her bankruptcy. The question was whether this was considered “property” of the bankrupt and/or “income” of the bankrupt at the time of bankruptcy. It was first determined that only the amount that applied to the year of bankruptcy was to be considered property at the time of bankruptcy. Amounts received for prior years were not considered property. They further concluded that income is determined on a cash basis and not an accrual basis. As the refund was not received until after the bankrupt was discharged, it was not considered income.