Value Received

A phrase usually employed in a bill of exchange or promissory note, to denote that a consideration has been given for it. These words are not necessary; 11 A. & E. 702; Mehlberg v. Tisher, 24 Wis. 607; though it is otherwise in some states if the bill or note be not negotiable; Bristol v. Warner, 19 Conn. 7; Hoyt v. Jaffray, 29 Ill. 104; extrinsic evidence is admissible between immediate parties to prove absence, failure, or illegality of consideration; Green v. Shepherd, 5 Allen (Mass.) 589; Aldrich v. Stockwell, 9 Allen (Mass.) 45. The expression value received, when put in a bill of exchange, will bear two interpretations; the drawer of the bill may be presumed to acknowledge the fact that he has received value from the payee; 3 Maule & S. 351; Benjamin v. Tillman, 2 McLean 213, Fed. Cas. No. 1,304; or when the bill has been made payable to the order of the drawer and accepted, it implies that value has been received by the acceptor; 5 Maule & S. 65; Thurman v. Van Brunt, 19 Barb. (N. Y.) 409. In a promissory note, the expression imports value received from the payee; 5 B. & C. 360; and sufficiently expresses a consideration; Moses v. Bank, 149 U. S. 298, 13 Sup. Ct. 900, 37 L. Ed. 743; although not necessarily in money; Osgood v. Bringolf, 32 Ia. 265. The words are not required by the Uniform Negotiable Instruments Act.

See Bill of Exchange.