WILLIAMS V. COMMISSIONER
28 T.C. 1000 (1957)
NATURE OF THE CASE: This was a dispute over the status of a note received as
compensation. Commissioner (P) determined a deficiency in D's income tax for 1951.
FACTS: Williams (D) was engaged in the business of locating marketable parcels of
timberland for prospective purchasers of timber. D did a deal with a firm in which he got as
payment for his services a note of $7,166.60 payable 240 days thereafter. D got that note on
May 5, 1951. D tried to sell the note to banks or finance companies and was unsuccessful. He
was unable to realize any money on the note until 1954 when he collected $6,666.66 upon the
discharge of the indebtedness. The IRS contended that the note represented income in 1951. D
claimed that the note had no fair market value and was not in payment of the indebtedness of
the parties involved.
ISSUE:
RULE OF LAW:
HOLDING AND DECISION:
LEGAL ANALYSIS:
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