In In re Marriage of Alter (2009) 171 Cal.App.4th 718, the court explained that "with noncash benefits, the court must make ad hoc determinations of the value, which are more complicated to do and could lead to inconsistent results. These concerns are not present with gifts of cash. Cash gifts are readily valued." (Alter, supra, at p. 734.) The court noted that while gifts are not included in federal income tax, the presumptive correctness of tax returns may, at the court's discretion, be rebutted by evidence of recurring gifts of cash that are a regular part of a parent's income. (Id. at pp. 734-735, 737.) The court determined the trial court reasonably included in the father's income $ 3,000 per month in cash that his mother gave him to pay his rent. (Id. at p. 737.) The court noted: "Jack's mother did not simply give him the benefit of living in the home; she gave him the money to pay for it. Thus, the benefit was easily valued and represented part of Jack's monthly cash flow." (Ibid.)