the fifth circuit reversed in part and affirmed in part the lower court decision. the court found that the agenda was related primarily to business, the details of the trip were primarily controlled by volkswagen, and that mr. gotcher's attendance was prompted by business considerations, primarily, to induce mr. gotcher to take interest in a volkswagen dealership when volkswagen was attempting to expand in the united states. thus, the primary benefit of the trip was to volkswagen as far as mr. gotcher was concerned, and thus the cost of trip was not income to him.