Chancer, a SA resident, occupied a position that required him to be entrusted with funds to be used for secret operations. Over a number of years he appropriated funds to himself and, in total, took about R450 000 from the trust fund. Chancer was ultimately caught, charged and 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 this assessment on the grounds that the amount was not 'received' by him and was therefore not gross income.

1. Discuss whether the R450 000 was or was not 'received by' Chancer