Tim's parents plan to provide him with $$50,000$ to support him while he establishes a new landscaping business. In exchange for the support, Tim will maintain the landscape at his father's business.

As the tax advisor to Tim and his parents, please prepare a memorandum to Tim and his parents explaining the relevant tax considerations for the proposed arrangement. In the memorandum, they will be interested in what conditions will the transfer of the $$50,000$ be included in Tim's gross income. Also, whether you have a recommendation for Tim and his parents on how to structure the arrangement tax efficiently for both Tim and his parents.

Tim's mother is a CPA, so will be interested in reviewing the underlying tax guidance in developing your memorandum, so please include applicable citations.