This section contains the nature of the case and procedural background.

D was a cash basis taxpayer who resided in Kentucky. D was employed by the Green Bay Packers. D won the Sports Magazine award for the most outstanding player in the NFL championship game of December 31, 1961. D got a Corvette but when the award was announced at the end of the game D merely accepted the award but did not demand immediate possession of the car. D was also told that a luncheon was to be held for him in New York City the following Wednesday and the award would be presented. The car was presented on January 3, 1962. The fair market value of the car was $3,331.04. D reported the sale in 1962 but did not include the market value of the car in his gross income for 1962. There were a number of issues in the case but the only one portrayed in the casebook was the issue of receipt of the property.

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