FACTS: Respondent taxpayer one received an automobile from a businessman. Respondent taxpayer two received a sum of money from an employer. Respondents did not include the transferred property in their gross incomes, deeming them gifts. A district court held that the automobile was remuneration for services rendered to the businessman. Another district court held that the sum of money was a gift. The appellate courts reversed the judgments. The court reversed the judgment in respondent one's case and vacated the judgment in respondent two's case.
The court refused to create a standard test because the conclusion of what constituted a "gift" under I.R.C. § 22(b)(3) required consideration of the factual circumstances surrounding the transfer, in particular the transferor's intent. The district court's determination that the transfer of the automobile was recompense for respondent one's services was not clearly erroneous, based upon the evidence. The judgment in respondent two's case was vacated because the district court's conclusory and general findings were insufficient for the appellate court to reverse its determination that the transfer of money was a gift.
CONCLUSION: The court reversed and vacated the judgments overturning the district courts' determinations as to whether the transfers to respondents constituted gifts.
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