2. Evaluation of non-cash receipts.
a. Objective View
i. Reg. 20.2031-1(b): the tax law generally adopts the purely objective standard of fair market value and accepts, as the value of a receipt, the price that would be reached in a transaction between a willing buyer and a willing seller. (Note; this is for estate tax)
ii. Reg. 1.61-2(d): basically, the fair market value (FMV) of the goods and services are going to be the determined amount. If the services are rendered at a stipulated price, such price will be presumed to be the FMV of the compensation received in the absence of evidence to the contrary.
iii. Rooney v. Commissioner (1987): says retail value of the ticket.
b. Subjective View
i. Turner v. Commissioner: only had to pay for half of the retail cost of ticket. This employs the subjective evaluation; the taxpayer would have never bought the ticket so the court reduced the amount.
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