In a recent case, a taxpayer who returned income on a cash basis attempted to argue that notwithstanding he received a transfer of land in one income year as consideration for services performed in an earlier income year, that it was the value of the land at the time of performance of the services in the earlier income year that should be returned as assessable income. However in accordance with general principle the Full Bench of the Federal Court upheld the decision by the earlier tribunal that for a cash taxpayer, income is derived when it is paid. In this case the income was paid at the time the transfer of land took place and hence it was the value of the land at that time and not at the time the services were performed that was required to be included in his assessable income.This is in line with general taxation law principles so it is difficult to see why the taxpayer bothered to challenge this determination.