[1] It is notable (and thus appears frequently in law school casebooks) for the following holdings: The Court was presented with two sets of facts.

After receiving some particularly helpful information, Berman decided to give Duberstein a gift of a Cadillac.

Mohawk Metal Corporation later deducted the value of the car as a business expense, but Duberstein did not include the value of the Cadillac in his gross income when he filed his tax return, deeming it a gift.

As a "gratuity" the corporation's directors awarded Stanton $20,000 in appreciation of the services rendered.

Justice William J. Brennan, Jr., for the majority, upheld the Tax court's ruling with regard to Duberstein: Duberstein's car was not a gift, because the motives were certainly not "disinterested"—it was given to compensate for past customer references or to encourage future references.

A plurality remanded Stanton's situation back to the trial court, to determine whether the Vestry intended to give the money as a gift or as compensation.

The Court also rejected the premise that there is a bright line as to what constitutes a gift for taxation purposes.

While siding with the majority on Duberstein, Justice Black believed that Stanton's money was a gift.

While siding with the majority on Duberstein, Justice Frankfurter believed that Stanton's money was definitely not a gift because it was given to him as a result of his hard work.