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Diamond Jim III was a very special rockfish. He had a valuable identification tag placed on him on June 19, 1958, and was let loose in the Chesapeake Bay by employees of American Brewery with the cooperation of Maryland state game officials. According to the well-published rules of the Third Annual American Beer Fishing Derby, anyone who caught Diamond Jim III and presented him to the company, with the ID tag and an affidavit that he had been caught with hook and line, would be entitled to a cash prize of $25,000. Other fish with lesser prizes were also let go. Simmons caught Diamond Jim III on August 6, 1958. At first, Simmons was not aware of his find but after examining the tag, he realized he had caught the $25,000 fish. Simmons complied with the terms of the offer, and after getting his prize, his silent partners, the Internal Revenue Service come forward to assert that the case prize was to be included in Simmons’ gross income. The IRS assessed a tax deficiency of $5,230. Simmons paid the claim but filed for a refund. Simmons (P) sued the Government (D) on the theory that no part of the cash prize could be included in income as it was a gift under section 102 pertaining to gifts in the Code. D filed a motion for summary judgment and P appealed.

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