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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
me we should engage in a case-by-case analysis, the touchstone of which is "the 'transferor's intention.' " Id. at 285-86, 80 S.Ct. at 1197 (quoting Bogardus v. Commissioner, 302 U.S. 34, 43, 58 S.Ct. 61, 65, 82 L.Ed. 32 (1937)). After reading Duberstein, a reasonable taxpayer would conclude that payment
2 mentions1 same-page
Page ?Same page
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
me we should engage in a case-by-case analysis, the touchstone of which is "the 'transferor's intention.'" Id. at 285-86, 80 S.Ct. at 1197 (quoting Bogardus v. Commissioner, 302 U.S. 34, 43, 58 S.Ct. 61, 65, 82 L.Ed. 32 (1937)). After reading Duberstein, a reasonable taxpayer would conclude that payments
2 mentions1 same-page
Page ?Same page
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
me we should engage in a case-by-case analysis, the touchstone of which is "the 'transferor's intention.' " Id. at 285-86, 80 S.Ct. at 1197 (quoting Bogardus v. Commissioner, 302 U.S. 34, 43, 58 S.Ct. 61, 65, 82 L.Ed. 32 (1937)). After reading Duberstein, a reasonable taxpayer would conclude that payment
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2 mentions1 same-page
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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
e we should engage in a case-by-case analysis, the touchstone of which is "the 'transferor's intention.' " Id. at 285-86, 80 S.Ct. at 1197 (quoting Bogardus v. Commissioner, 302 U.S. 34, 43, 58 S.Ct. 61, 65, 82 L.Ed. 32 (1937)). After reading Duberstein, a reasonable taxpayer would conclude that payments
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