Simmons v. United States
United States Court of Appeals for the Fourth Circuit
308 F.2d 160 (1962)
Relevant factsFree
American Brewery publicized a contest promising $25,000 to whoever caught a specially tagged fish and presented proof, and Simmons (plaintiff), aware of the contest though not specifically fishing for the tagged fish, caught it and promptly complied with the contest rules to claim the prize; the IRS sought to tax the winnings as income, and Simmons argued the payment was a nontaxable gift.
IssueFree
Whether a prize is considered a gift if it was not motivated out of affection, respect, admiration, charity, or similar impulses.