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This section contains the nature of the case and procedural background.

P is a self-employed attorney who specializes in workers' compensation cases for police and fire officials. P is a retired police officer. P successfully represented Keith Walker, a former police officer who was injured in the line of duty. P represented Mr. Walker from the commencement of the suit in 1994 through its conclusion in 2008, and Mr. Walker received a lump-sum payment exceeding $360,000 consisting of accrued pension benefits. P received a $2,500 'flat fee' paid by Mr. Walker at the outset of the lawsuit in 1994. After the lawsuit concluded P received a check for $30,000 from Mr. Walker, which he deposited into his personal checking account on November 10, 2008. P did not report the $30,000 on the joint return. P contends that the $30,000 was a nontaxable gift. Although Mr. Walker considered P more than just his attorney but also a friend, he would not have given $30,000 to P if he had not received the lump-sum payment. D disallowed the $30,000 gift. At trial, P did not produce a fee agreement or any other documentation regarding P's representation of Mr. Walker. D disallowed the $30,000 gift.

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