Poyner v. Commissioner

Poyner v. Commissioner 301 F.2d 287 is a United States tax law case that discusses whether "special death benefits" paid to an employee's widow are exempt from taxes as a gift under §102.
It produces five factors as a pertinent test:

whether the payments were made to the spouse of the deceased shareholder, not to his estate;
whether the payor had been under no obligation to make the payments and had, in fact, decided on previous occasions not to make payments to persons qualified;
whether the company derived benefit of an economic nature from the payments;
whether the recipient had ever performed any services for the company;
whether the services of the deceased employee had been fully compensated during his lifetime.