$1\mathrm{.}4.$ Chancer, a SA resident, occupied a position that required him to be entrusted with funds tobe used for secret operations. Over a number of years he appropriated funds to himself and,in total, took about R$450000$ from the trust fund. Chancer was ultimately caught, chargedand ordered to repay the whole amount, which he subsequently did.Chancer was then assessed to tax on the amount he had stolen. Chancer objected to thisassessment on the grounds that the amount was not received by him and was therefore notgross income.REQUIRED:Discuss whether the R$450000$ was or was not received by Chancer. $(7)$