United States Tax Court
47 T.C. 428 (1967)
In 1961, Hornung (plaintiff) was a football player for the Green Bay Packers. On December 31, 1961, Hornung played in the National Football League (NFL) championship game in Green Bay, Wisconsin. After the game, Sport Magazine (Sport) named him the outstanding player of the game. Sport is a New York publication that annually awards a new Corvette to athletes for outstanding performance. Sport announced the award to Hornung immediately after the game. Hornung agreed to appear at a luncheon in New York City a few days later to officially accept the car. Sport did not make the car available to Hornung on the day of the game. Hornung did not receive a key or title to the car, and no arrangements were made for Hornung to receive the car prior to the luncheon. At the time, the car was held at a New York dealership that was closed the day of the game. Although in previous years, Sport made the car available for pick up in New York on the day of the game, Sport did not believe the winner of the car would choose to travel from Green Bay to New York City immediately after the game. On January 3, 1962, Hornung accepted the car in New York City. Hornung did not report the car as income in 1962 or any other year. The Commissioner (defendant) determined the value of the car should have been included in Hornung’s gross income for 1962.
Rule of Law
Holding and Reasoning (Hoyt, J.)
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