2. Stanton received a large amount of money as a gratuity after he resigned his employment of ten years with a church.
2. Was Stanton's money received a gift?
2. Facts were not sufficient.
-Transferor's intention must be decided on a "case by case" basis. (Question of fact).
-Gifts result from a "detached and disinterested generosity" and are often given out of "affection, respect, admiration, charity, etc."
-Contrasts gifts with payments given as an "involved and intensely interested" act.
Class: Federal Income Taxation