 Paul Hornung, a football player for the Green Bay Packers, won a Corvette as a prize on December 31, 1961, for his performance in the 1961 NFL Championship Game.The game was played in Green Bay, Wisconsin, the car was kept at a dealership in New York City, and Hornung did not retrieve the car until January 3, 1962.The court decided that Hornung had not constructively received the car (income) in 1961 because, under the circumstances, it would have been unreasonable to expect him to retrieve the car on the day he won it.