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.

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