Commissioner v. Duberstein

In two consolidated cases: Duberstein (defendant) received a car from a business associate as a token of appreciation for valuable customer tips, which the paying company deducted as a business expense; and Stanton (defendant), a longtime church employee, received a resolution granting him $20,000 in installments upon voluntarily resigning, framed as appreciation for his services though the church had no legal obligation to pay it. Both men excluded the payments as gifts; the Tax Court found Duberstein's transfer wasn't a gift while the district court found Stanton's transfer was a gift, and the courts of appeals reversed both rulings in opposite directions, prompting Supreme Court review to clarify the gift standard.