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Promissory notes or other evidences of indebtedness received as payment for services constitute income, within the meaning of section 22(a) of the 1939 Code, to the extent of their fair market value. Regs. 118, sec. 39.22(a)-4. Cf. Schlemmer v. United States, 94 F. 2d 77; Robert J. Dial, 24 T. C. 117; San Jacinto Life Insurance Co., 34 B. T. A. 186; Great Southern Life Insurance Co., 33 B. T. A. 512, affd. 89 F. 2d 54, certiorari denied 302 U.S. 698. 


A note received only as security, or as an evidence of indebtedness, and not as payment, may not be regarded as income at the time of receipt. Schlemmer v. United States, supra; Robert J. Dial, supra. A simple change in the form of indebtedness from an account payable to a note payable is insufficient to cause the realization of income by the creditor. 

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