Alden D. Stanton and Louise M. Stanton v. United States

In Helvering v. American Dental Co., 318 U.S. 322, 327, 63 S.Ct. 577, 580, 87 L.Ed. 785, it was said: “The narrow line between taxable bonuses and tax free gifts is illuminated by Bogardus v. Commissioner, 302 U.S. 34, 58 S.Ct. 61, 82 L.Ed. 32, on the one side and upon the other by Noel v. Parrott, 4 Cir., 15 F.2d 669, as approved in Old Colony Trust Co. v. Commissioner, 279 U.S. 716, 730, 49 S.Ct. 499, 73 L.Ed. 918.” In my analysis the case here is far closer to Bogardus than to Noel.

In Bogardus v. Commissioner, 302 U. S. 34, 58 S.Ct. 61, 82 L.Ed. 32, it is true that the majority opinion…