[2] As evidence by several letters from Kritzik to Harris, the sisters showered him with great amounts of affection.

[4] In separate criminal trials, Harris and Conley were convicted of willfully evading their income tax obligations regarding the money.

The principal issue at trial was the nature of the payments Kritzik made to Conley and Harris.

[2] The Court reversed Harris’ and Conley's convictions and remanded the case with instructions to dismiss the indictments against them.

[8] Though citing Commissioner v. Duberstein[9] as the "definitive statement" on the distinction between gifts and income, the Court concluded that it provided no answer to the taxability of "transfers of money to a mistress in the context of a long term relationship.