In two cases, consolidated for decision, the Court articulated the test to be used when deciding whether an item of income or a gift and therefore not income tax. Both cases are colorful. The first involves the unsolicited sending of a Cadillac. The second involves the transfer of much-photographed Trinity Church, which sits at the end of Wall Street.

In two cases, consolidated for decision, the Court articulated the test to be used when deciding whether an item of income or a gift and therefore not income tax. Both cases are colorful. The first involves the unsolicited sending of a Cadillac. The second involves the transfer of much-photographed Trinity Church, which sits at the end of Wall Street.
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Henry B. Reiling
Source: Harvard Business School
6 pages.
Publication Date: Jun 25, 1984. Prod #: 284074-PDF-ENG
Commissioner vs. Duberstein HBR case solution