The holding of Duberstein v. Commissioner, stands for the following proposition:

a) A gift for income tax purposes is the same as for gift tax purposes.

b) A gift for income tax purposes is motivated out of detached and disinterested generosity, love, affection, charity or like impulses, thus is not likely to be found in a business setting.

c) A gift made in the business setting is always deductible by the donor.

d) None of the above.