- 38 - issued to him a store credit in lieu of the computer. Nonetheless, petitioners contend that their income should not be increased by the value of the prize because the computer had no economic value or benefit to petitioner and because they never used all of the store credit. Generally, gross income includes prizes and awards received by a taxpayer during the year. See sec. 74(a); Hornung v. Commissioner, 47 T.C. 428, 435-436 (1967); McCoy v. Commissioner, 38 T.C. 841, 843 (1962); sec. 1.74-1(a)(1), Income Tax Regs. When the prize awarded is not money but goods or services, the fair market value of those goods or services is the amount to be included in income. See McCoy v. Commissioner, supra; Wade v. Commissioner, T.C. Memo. 1988-118; sec. 1.74-1(a)(2), Income Tax Regs. We have noted: In valuing taxable prizes and awards for Federal income tax purposes, courts do not always adopt the same methodology. In some situations, the retail value of prizes and awards is used. In other situations, a wholesale or other discounted value is used. Objective factors are emphasized, but subjective factors also are given weight in determining the value of prizes and awards to particular taxpayers. [Wade v. Commissioner, supra; citations omitted.] Petitioners deny that the fair market value of the prize petitioner actually received was $2,223. In their briefs, petitioners maintain that petitioner and Computerland never agreed on the “retail value” of the prize and that petitioner “received a carefully hedged ‘retail’ value for the prize, butPage: Previous 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 Next
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