You are a CPA with a very wealthy client, Ms. Atsushi Trong, who is a model of the U.S. success story. She immigrated to the United States as a teenager and studied clothing trends in both high school and college. She started her own clothing company, which has been very successful. She has a net worth of over $100 million and no immediate family. She decided to plow some of her good fortune back into the educational system, which provided the intellectual foundation for her success. She selected the current class of her old high school, and in 2019 gave each of 100 graduating students $100,000 to be used to pay tuition costs for four years at her college alma mater. Each of the 100 student donees used the $100,000 to prepay the four-year tuition costs in 2019. You have been asked to determine the tax consequences of these transactions. What position would you take after considering the requirements of the IRC and Statements on Standards for Tax Services (reproduced in Appendix E)?