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return for services rendered" rather than "out of affection, respect, admiration, charity or like impulses." Id. at 285, 80 S.Ct. at 1197 (quoting Robertson v. United States, 343 U.S. 711, 714, 72 S.Ct. 994, 996, 96 L.Ed. 1237 (1952)). 42 Viewed in this light, I suggest that the bulk of the tax court ca
hip consists of something more than specific payments for specific sessions of sex." Ante at 1133-1134. I respectfully disagree. In Commissioner v. Duberstein, 363 U.S. 278, 80 S.Ct. 1190, 4 L.Ed.2d 1218 (1960), the font of our analysis of the gift/income distinction, the Supreme Court expressly eschewed t
return for services rendered" rather than "out of affection, respect, admiration, charity or like impulses." Id. at 285, 80 S.Ct. at 1197 (quoting Robertson v. United States, 343 U.S. 711, 714, 72 S.Ct. 994, 996, 96 L.Ed. 1237 (1952)). 42 Viewed in this light, I suggest that the bulk of the tax court c
hip consists of something more than specific payments for specific sessions of sex." Ante at 1133-1134. I respectfully disagree. In Commissioner v. Duberstein, 363 U.S. 278, 80 S.Ct. 1190, 4 L.Ed.2d 1218 (1960), the font of our analysis of the gift/income distinction, the Supreme Court expressly eschewed t
return for services rendered" rather than "out of affection, respect, admiration, charity or like impulses." Id. at 285, 80 S.Ct. at 1197 (quoting Robertson v. United States, 343 U.S. 711, 714, 72 S.Ct. 994, 996, 96 L.Ed. 1237 (1952)). 42 Viewed in this light, I suggest that the bulk of the tax court ca
hip consists of something more than specific payments for specific sessions of sex." Ante at 1133-1134. I respectfully disagree. In Commissioner v. Duberstein, 363 U.S. 278, 80 S.Ct. 1190, 4 L.Ed.2d 1218 (1960), the font of our analysis of the gift/income distinction, the Supreme Court expressly eschewed t
n return for services rendered" rather than "out of affection, respect, admiration, charity or like impulses." Id. at 285, 80 S.Ct. at 1197 (quoting Robertson v. United States, 343 U.S. 711 714, 72 S.Ct. 994, 996, 96 L.Ed. 1237 (1952)). 42 Viewed in this light, I suggest that the bulk of the tax court ca
hip consists of something more than specific payments for specific sessions of sex." Ante at 1133-1134. I respectfully disagree. In Commissioner v. Duberstein, 363 U.S. 278, 80 S.Ct. 1190, 4 L.Ed.2d 1218 (1960), the font of our analysis of the gift/income distinction, the Supreme Court expressly eschewed t
Entities connected to both Robertson and Duberstein