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

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.

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.