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

P was employed by the Hotpoint Appliance Sales. Hotpoint sponsored an annual sales contest and distributed awards to the winners. In 1956, P received a new 1957 Lincoln Capri two-door coupe automobile. At the time of the award, the 1957 Lincoln models had been on the market about 1 month. The cost of the automobile to Hotpoint was $4,452.54. P drove it home and went to an authorized Lincoln-Mercury dealer in that city to get an appraisal of the automobile, the result of which is not disclosed by the record. Within 10 days after receiving the Lincoln car, P traded it to a dealer for $1,000 in cash and a 1957 Ford Country Squire station wagon with power equipment, having a dealer's price of $2,600. Petitioner included in his adjusted gross income for the year 1956 the amount of $3,600 as the value of the Lincoln automobile. Hotpoint reported the payment of additional compensation to P in the amount of $4,452.54, which was the cost to it of the Lincoln automobile. D determined that P had additional income of $852.54, stating that 'the fair market value of a Lincoln Capri automobile which you received as a prize or award * * * was $4,452.54 rather than the amount of $3,600 which was included in the income reported in your return on account thereof.' P sued contesting the deficiency.

The legal issues presented in this case will be displayed here.

The court's holding and decision will be displayed here.

Legal analysis from Dean's Law Dictionary will be displayed here.