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issue a Form W-2, and deducted the entire cost as an “Employee
Relations” or “Customer Ref” expense. We nonetheless reiterated
that “Whether the golf clubs were given to Mr. Heemskerk as a
gift or for services rendered must be determined from all the
facts and circumstances.” Id. After pointing out that “A
voluntarily executed transfer of property by one to another,
without any consideration or compensation therefor, is not
necessarily a gift within the meaning of section 274(b)”, we
concluded that the company had “purchased the golf clubs for Mr.
Heemskerk as an incentive for future performance and in
appreciation for his past services to the company.” Id. A full
deduction was permitted under section 162(a). See id.
We are similarly convinced that the $100 bills here were in
fact given in recognition of services performed. When relatively
small cash payments are made to a significant number of non-
shareholder employees, and only to employees, we are hard pressed
to infer that their labors for the employer were not the
underlying motivation. This is not a case which presents a
situation of potential disguised dividends to owners, the more
typical context for challenges to the deductibility of an alleged
bonus. See Owensby & Kritikos, Inc. v. Commissioner, 819 F.2d
1315, 1324 (5th Cir. 1987), affg. T.C. Memo. 1985-267;
Labelgraphics, Inc. v. Commissioner, T.C. Memo. 1998-343, affd.
221 F.3d 1091 (9th Cir. 2000). We therefore hold that the
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