Only those methods of accounting which clearly indicate the taxpayer's income will be accepted. All items of gross income and all deductions must be treated with reasonable consistency. All items of gross income subject to taxation shall be included in gross income for the tax year in which they are received by the taxpayer, unless in order to clearly reflect income such amounts are to be properly accounted for as of a different period. See ACA 26-51-404(a)(2). For instance, in a case where it is necessary to use an inventory, no other accounting method with respect to purchases and sales will correctly reflect income except an accrual method. A taxpayer is deemed to have received items of gross income which have been credited to or set apart for him without restriction. On the other hand, appreciation in value of property is not an accrual of income to a taxpayer prior to the realization of such appreciation through sale or conversion of the property.
1.26 Ark. Code R. 51-401(a)