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Income Tax Keyed to Lind
Hornung v. Commissioner
Facts
Petitioner is a well-known football player for the Green Bay Packers and resides in Louisville, Kentucky. Each year Sports Magazine awards a new Corvette car to the player selected by its editors as the outstanding players in the National Football League championship game. The car is usually purchased several months before the award is given. The game was played on December 31, 1961 and Petitioner was awarded the car for his performance. He accepted the award but did not take possession. The car was not available for pickup that day because it was located at a dealership in New York that was closed on Sunday. He received the car on January 3, 1962. Petitioner sold the car and reported the income from the sale as gain on his 1962 tax return. He did not include the fair market value of the car on his gross income in any tax year.
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