Violet A. Reynolds - Page 13




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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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