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Document Mentions (4 shared documents)
2 mentions1 same-page
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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
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
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
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
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
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
Page ?Same page
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
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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