for an item to constitute taxable income to the taxpayer, there must be economic gain to the taxpayer, and the economic gain must primarily benefit the taxpayer personally. the gotchers received an indirect economic gain by receiving a benefit (the value of the trip) without any reduction in their wealth. the court considered the specific details of the trip, including the purpose of the trip, time spent in meetings, the location of day trips, and whether the trip was an award for past service. the court conducted this analysis for the purpose of determining whether the primary benefit of the trip was to the gotchers or whether the primary benefit of the trip was to volkswagen and the employers.