For tax year 2019, IRS readjusted the personal tax return of Taxpayer, Jane Smith ("Jane"), and assessed her an additional gross income of $225,000. When Jane filed her 2019 taxes, she did not report the $225,000 because she believed it was not taxable to her, if taxable at all. Now, Jane and the IRS are embattled in a dispute over whether the $225,000 belongs to Jane or another taxpayer or some other entity. Jane hires YOU to defend her. In 2019, Jane decided to help Emily and her grandparents. To that end, she organized a "Go Fund Me" fundraiser in name of Shannon and her deceased daughters to be used for the benefit of Emily. Through intensive marketing efforts, the fundraiser generated $225,000 to be used for the health, education, and maintenance of raising young Emily. Receipt of the online donations occurred in this matter: when a donor donated funds, their donation was transferred from the platform directly to a Trust's bank account. The Trust was formed as a Revocable Trust for the benefit of Emily and was set up for the purpose of receiving the Go Fund Me monies. The Grantor of the Trust was Jane and Jane was