Taxpayers were developers of retirement villages. They entered into an agreement with the potential occupants, in terms of which occupants advanced interest-free loans to the conpanies(which they used to finance the development of the units). In exchange, these occupants were entitled to oppcupy the units for remainder of his life but ownership of unit remain with companies. SARS contended that the value of the right to retain and use the loab capital interest free must be included in the amount.
The court held that the right to retain and use the loan capital interest-free for a period of time was an 'amount' in that it was a valuable right, which was capable of being valued in money even though it could not be turned into money. It is not the view that if a receipt cannot be turned into money, it has no money value. The test is objective, not subjective. Therefore, it had to be included in the taxpayers income.