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Wolder (D) entered into an agreement with Boyce whereby D would provide Boyce with legal services as she would require during her lifetime and upon her death bequeath certain property to D. When Boyce died, she gave D property as per the agreement that was worth $15,845. There was no dispute that D had rendered legal services to Boyce over her lifetime and had not billed her for those services. D argued that this legacy was specifically excluded under Section 102(a). D relied on case law that stated a bequest under 102(a) had not been restricted so as to exclude bequests made on account of some consideration flowing from the beneficiary to the decedent. The Tax Court held that the bequest constituted income under section 61 and was not exempt under section 102. This appeal resulted.

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