Williams v. Commissioner

28 T.C. 1000 (1957)

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Williams v. Commissioner

United States Tax Court
28 T.C. 1000 (1957)

SR
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Facts

Jay A. Williams (plaintiff) conducted a business in which he located parcels of timberland for prospective buyers. In 1951, Williams located parcels for a client, J.M. Housley, who was unable to pay at the time he received the information. Housley acknowledged his debt to Williams by issuing Williams an unsecured, non-interest-bearing promissory note for $7,166.60. Williams understood that Housley would be unable to honor the note until Housley purchased timber property and began making a profit from it. After receiving the note, Williams attempted about 10 to 15 times to sell it, but had no success. In 1954, Housley discharged the debt by paying Williams $6,666.66. Williams reported this amount in 1954. The Commissioner (defendant) determined that Williams should have reported the value of the note as income in 1951.

Rule of Law

Issue

Holding and Reasoning ()

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