Facts: Your client, a German named Werner visited his brother Klaus, who immigrated to the United States eight years ago and has been living in Washington, DC. At the time, Werner was under contract to a German soccer team and was expected to return to the team to begin play for the fall 2014.

Considerable encouragement from Klaus and the Redskins organization seemed to be in vain until the Redskins, at Klauss suggestion, offered Werner a $100,000 bonus. At this point, Werner signed a contract, which Klaus co-signed as a witness and interpreter.

Grateful to his brother for assisting as an interpreter and negotiator, and for encouraging him to stay, Werner instructed the Redskins to pay $15,000 of the negotiated bonus directly to Klaus. Klaus reported the $15,000 as other income on his 2014 income tax return and paid the appropriate tax.

After examining Werners 2014 tax return, the IRS made a deficiency assessment claiming that the $15,000 paid to Klaus constituted income to Werner and should thus be included in his income. Your manager has asked you to prepare a tax research memo indicating if the $15,000 should be included in taxable income for Werner.

FROM STUDENT: Please guide me to the correct tax code and court citation to answer this. Thanks