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

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

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

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