3. Purpose of non-cash receipt.
i. McCann v. United States (1983):  π was taxed because the trip to Vegas was primarily for pleasure.
ii. United States v. Gotcher (1968):  π was not taxed because the trip to Germany was to see the VW plant and was primarily business.
b. Factors:
i. What was the trip primarily for?
1. reward?/fun?/business?/sales pitch?
ii. For whose benefit was the trip primarily for?
1. person?/company?
iii. Did you have to go on the trip?:
iv. Who had control over the trip?
1. Where was most of your time spent?
2. What did you do for most of the time?
v. Who set the schedule?
1. person?/company?