for income tax purposes, the case is notable for the articulation of the "primary benefit to the provider doctrine." if individual receives an economic gain, but the primary benefit is to the provider of the gain, then such gain is not income to the individual. the articulation of the doctrine is open to question, as almost all payments could be characterized as providing the primary benefit to the provider. a business only pays employees for the benefit of labor which will provide greater returns than expenses and contract consideration is only furnished to receive a preferred gain. however, employee income (as compensation for services) and contract consideration (as compensation for services, gains from dealings in property, and many other categories) are regularly taxed.