Payments made to a widow by a corporation of which her deceased husband had been an officer, director and shareholder are not gifts unless they proceed out of generosity, affection, respect, admiration, charity or like impulses.
Smith v. Commissioner of Internal Revenue, 305 F.2d 778 (3d Cir. 1962).
Taxation - Income vs. Gift - Payments to Widow of Officer-Stockholder,
Duq. L. Rev.
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