Rick Beam is an independent sales representative for different textile manufacturers. Products that he is involved with is soft goods including tablecloths, curtains as well as drapes. Clothing store chains, department stores as well as small speciality stores are Rick Beams customers. The employees of the companies who are responsible for purchasing merchandise from Rick Beam are known as the buyers. Generally, these different companies prohibit buyers from accepting gifts from manufacturing sales representatives.

Every year, Rick Beam gives cash gifts, that are never more than $25$ Dollars, to most buyers that are his customers. He usually cashes a large check in November and gives cash personally to his buyers around Christmas time. Rick Beams deductions for these cash gifts have been disallowed by the IRS, based on Code Section $162($c$)(2).$