American Brewery, Inc. sponsored a fishing contest. One fish in the Chesapeake Bay, called Diamond Jim, was given a special identification tag. Anybody who caught the fish and presented it to the brewery, together with the identification tag and an affidavit, would be entitled to a cash prize of $25,000.00. These rules were well-publicized. William Simmons (plaintiff) caught the prized fish. Although Simmons knew about the contest, he did not set out to catch the prized fish. After catching the fish, Simmons quickly complied with the conditions of the contest. The brewery awarded Simmons the $25,000 prize. The Internal Revenue Service sought to have the $25,000 included in Simmons’ gross income, thus rendering the prize taxable. Simmons argued that the prize was not taxable on the ground that the prize was given to him as a gift. Simmons brought suit against the government (defendant) in federal court. The trial court ruled in favor of the government. Simmons appealed.