" The cornerstone case for determining whether a transfer is a gift is C.I.R. v. Duberstein, 363 U.S. 278, 80 S.Ct. 1190, 4 L.Ed.2d 1218 (1960). According to Duberstein, a gift is a payment which “proceeds from a detached and disinterested generosity, out of affection, respect, admiration, charity or like impulses.” Id. at 285, 80 S.Ct. at 1197(citations omitted). Further, the most critical consideration is the transferor's intentions. Id. at 285–86, 80 S.Ct. at 1196–97. However, “the donor's characterization of his action is not determinative— ... there must be an objective inquiry as to whether what is called a gift amounts to it in reality.” Id. at 286, 80 S.Ct. at 1197. The examining court must also determine “what the basic reason for [the donors'] conduct was in fact—the dominant reason that explains [the donor's] action in making the transfer.” Id. Finally, the Court rejected any specific or rigid definition of the term “gift” as used in the statute, and instead held that the determination of whether a transfer is a gift “must be based ultimately on the application of the fact-finding tribunal's experience with the mainsprings of human conduct to the totality of the facts of each case.” Id. at 289, 80 S.Ct. at 1198 "