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(1986), 1986-3 C.B. (Vol. 3) 1, 49. Clearly, the amounts
received by petitioner do not fall within the narrow exception
intended for purely personal reasons. Accordingly, under section
102(c)(1), petitioner would not be entitled to treat the amounts
received as excludable from gross income.
Furthermore, the record does not support a finding that Dr.
Deland, based on detached and disinterested generosity and out of
affection, respect, and admiration, intended to make gifts to
petitioner. Commissioner v. Duberstein, 363 U.S. 278, 285
(1960). The facts in this case reflect that the amounts paid to
petitioner were in exchange for her high-quality performance as
an employee. The amounts were paid as bonuses after evaluation
of her performance by the corporation’s chief operating officer
and his recommendation of the bonus amounts. The recommended
amounts were approved by Dr. Deland, the person who petitioner
alleges made the alleged gifts.
It is clear from this record that petitioner was a key
employee and that the amount she received in each of the 3 years
was earned and commensurate with the bonuses paid to other
employees, including Mr. Sullivan. Petitioner has placed much
emphasis on the fact that Dr. Deland was a personal friend, and
she contends that the friendship was the source of disinterested
generosity to support a gift. Dr. Deland’s approval and payment
of the amounts in question, however, were not out of
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