United States Tax Court
38 T.C. 841 (1962)
Lawrence McCoy (plaintiff) won a sales contest. McCoy’s employer awarded him a new car that the employer had bought less than a month earlier. After receiving the car, McCoy drove it on a long trip and then had it appraised for less than the $4,452.24 that the employer had paid for the car. McCoy sold the award car for $1,000 and bought another car for $2,600. McCoy included $3,600 in his gross income, reasoning that this was the fair market value of the award at the time he included the award in his gross income. McCoy also reasoned that even when he received the award car less than a month after the employer bought it, the award car was worth less than $4,452.24 to the employer because a new car’s resale value would always be lower than its original price, even before the car received any use. The commissioner of internal revenue (commissioner) (defendant) determined that McCoy’s gross income should have included the full price that McCoy’s employer paid for the award car, rather than the car’s value at the time of the award or after McCoy’s use of the car. McCoy filed a petition challenging the commissioner’s determination.
Rule of Law
Holding and Reasoning (Atkins, J.)
What to do next…
Unlock this case brief with a free (no-commitment) trial membership of Quimbee.
You’ll be in good company: Quimbee is one of the most widely used and trusted sites for law students, serving more than 97,000 law students since 2011. Some law schools—such as Yale, Vanderbilt, Berkeley, and the University of Illinois—even subscribe directly to Quimbee for all their law students. Read our student testimonials.
Learn more about Quimbee’s unique (and proven) approach to achieving great grades at law school.
Quimbee is a company hell-bent on one thing: helping you get an “A” in every course you take in law school, so you can graduate at the top of your class and get a high-paying law job. We’re not just a study aid for law students; we’re the study aid for law students. Read more about Quimbee.
Here's why 219,000 law students have relied on our case briefs:
- Written by law professors and practitioners, not other law students. 14,100 briefs, keyed to 189 casebooks. Top-notch customer support.
- The right amount of information, includes the facts, issues, rule of law, holding and reasoning, and any concurrences and dissents.
- Access in your classes, works on your mobile and tablet. Massive library of related video lessons and high quality multiple-choice questions.
- Easy to use, uniform format for every case brief. Written in plain English, not in legalese. Our briefs summarize and simplify; they don’t just repeat the court’s language.