Howard Veit (plaintiff) was the executive vice president of a cotton-goods company in 1939 and 1940. The company paid Veit a fixed salary during these years, plus a bonus of 10 percent of the company’s profits for each respective year. The company was originally obligated to pay the bonuses for both years in 1941. In 1940, Veit desired to work less, and the company agreed to restructure his working obligations. One of the bargained-for terms of Veit’s employment agreement was that the 1940 bonus payment was to be deferred until 1942. The commissioner of internal revenue (commissioner) (defendant) believed that Veit had constructively received the 1940 bonus in 1941 and that the new agreement was ineffective to delay the bonus payment for tax purposes. Veit petitioned the United States Tax Court for a redetermination.