Schiff, a self-styled tax rebel who had made a career out of his tax protest activities, appeared live on the February 7, 1983, CBS News Nightwatch program. During the course of the program, which had a viewer participant format, Schiff repeated his long-standing position that "there is nothing in the Internal Revenue Code which says anyone is legally required to pay the tax." Later in the program, Schiff stated: "If anybody calls this show and cites any section of this Code that says an individual is required to file a tax return, I will pay them $100,000." Newman, an attorney, did not see Schiff live on Nightwatch, but saw a two-minute taped segment of the original Nightwatch interview several hours later on the CBS Morning News. Certain that Schiff's statements were incorrect, Newman telephoned and wrote CBS Morning News, attempting to accept Schiff's offer by citing Internal Revenue Code provisions requiring individuals to pay federal income tax. CBS forwarded Newman's letter to Schiff, who refused to pay on the ground that Newman had not properly accepted his offer. Newman sued Schiff for breach of contract. Will Newman win?