Around October 3, 1947, Victor R. Wolder (defendant) and Marguerite K. Boyce entered an agreement. The agreement specified that Wolder, an attorney, would provide legal services for Boyce free of charge for the rest of her life. In return, Boyce would bequeath any securities she might obtain should a corporation by the name of White Laboratories undergo a merger or consolidation. White Laboratories subsequently merged with Schering Corporation. Boyce received 750 shares of one type of stock and 500 shares of another. Boyce later exchanged the 500 shares for $15,845. Over the course of Boyce’s life, Wolder upheld the agreement by providing legal services without charge. Boyce also upheld the agreement by bequeathing to Wolder her 750 shares and the $15,845. The Tax Court held that the fair market value of the shares and the $15,845 was taxable income for services rendered, and not a bequest exempt from taxation.