12. Income contrasted with capital.

The relation of a receipt or profit, not itself specifically charged, to a designated source from which it is derived must, in order to render it taxable, be of a revenue or income nature, as distinct from an accretion of capital. The test is the quality of the payment in the hands of the recipient1. While the treatment of an item in a taxpayer's business accounts, or in contemporary correspondence or other documents, may be indicative of its nature, it is not conclusive as to its intrinsic quality2. The fact that a receipt in the nature of compensation is