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