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furniture, fur coats, and other clothing. Respondent determined
that the money and other assets were taxable to the woman as
compensation for services rendered to the man. We disagreed. We
held that the woman received the money and other assets as gifts.
See also Libby v. Commissioner, T.C. Memo. 1969-184 (similar
holding as to cash and property given to a young mistress by her
older paramour).
Later, in Pascarelli v. Commissioner, 55 T.C. 1082,
1090-1091 (1971), affd. without published opinion 485 F.2d 681
(3d Cir. 1973), we held to the same effect. There, the taxpayer
was a woman who lived with a man who was not her husband. The
man gave money to the woman in exchange for "wifely services".
Respondent determined that the money was taxable to the woman as
compensation that she earned for her services. We disagreed. We
held that the payments were gifts. We found that the man paid
the money to the woman "motivated by sentiments of affection,
respect, and admiration". Id. at 1091.
And later, in Reis v. Commissioner, T.C. Memo. 1974-287, the
taxpayer was a young female nightclub dancer who met an older man
when he bought dinner and champagne for the performers in the
show. The man paid each person at the table, other than the
woman, $50 to leave the table so that he and she would be alone.
The man gave the woman $1,200 for a mink stole and another $1,200
so that her sister could have an expensive coat too. Over the
next 5 years, the woman saw the man "every Tuesday night at the
[nightclub] and Wednesday afternoons from approximately 1:00 p.m.
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