I have a client that has a contract sale due 12/31/12 and the payoff is $1,000,000 with only $50,000 CB and we are looking for some tax shelter ideas. Oil and Gas have been explored but are there others. If the payoff doesn’t happen until 2013 could they still declare the income this year being a better year for taxes? Woul;d they get hit with the medicare tax of 3.6% or 3.8% whatever it is?