Nature of the Case
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Facts
Williams (D) was engaged in the business of locating marketable parcels of timberland for prospective purchasers of timber. D did a deal with a firm in which he got as payment for his services a note of $7,166.60 payable 240 days thereafter. D got that note on May 5, 1951. D tried to sell the note to banks or finance companies and was unsuccessful. He was unable to realize any money on the note until 1954 when he collected $6,666.66 upon the discharge of the indebtedness. The IRS contended that the note represented income in 1951. D claimed that the note had no fair market value and was not in payment of the indebtedness of the parties involved.
Holding and Decision
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Legal Analysis
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