Property Purchase or Payment in Kind? The Oxford Paper Conundrum.

The article tries to solve the question whether Purchase Model or Fee Model should be applied in the scenario where a taxpayer undertakes an obligation or assumes a liability and in exchange receives property. It mentions that in an income tax system that ignores contingent liabilities, there is no right answer to the question. It also states that tax courts should not conclude which model is to be used and concludes that an approach where several factors are weighed properly should be used.