Before getting into the case, there is an important statement made in the headnote. It states the definition of income; which is the compensation for services-distinguished from gift-retirement or resignation-relationship of specific services. Whether that income is taxable is left for question. The case is concerning the provision of the Internal Revenue Code, that excludes from gross income the value acquired by a gift. The facts of the case are as follows. Duberstein was the head of the Duberstein Iron & Metal Company, who is the taxpayer focused on in this case. Duberstein had done much business with Berman, the president of Mohawk Metal Corporation. Both of these individual companies had headquarters is different states. Berman testified
