In Commissioner v. Duberstein, 363 U.S. 278, 80 S.Ct. 1190, 4 L.Ed.2d 1218 (1960), the Supreme Court, while refusing to accede to the Government's suggestion that a new test be promulgated to serve as a standard to be applied by the lower courts and by the Tax Court in dealing with the numerous cases presenting the gift vis-a-vis taxable income question, did review the law in this area. As we understand the teachings of Duberstein, the critical consideration is the transferor's intention, or, as stated by the Court, 'we take it that the proper criterion, established by decision here, is one that inquires what the basic reason for his (transferor) conduct was in fact-the dominant reason that explains his action in making the transfer.' 363 U.S. at 286, 80 S.Ct. at 1197, 4 L.Ed.2d 1218. The Court did not spell out or limit the factors to be considered in resolving the motive or reason which prompted the transferor to make the payment, but stated that 'the conclusion whether a transfer amounts to a 'gift' is one that must be reached on consideration of all the factors.' 363 U.S. at 288, 80 S.Ct. at 1198, 4 L.Ed.2d 1218. The Supreme Court said (page 289 of 363 U.S., page 1198 of 80 S.Ct.): " Decision of the issue presented in these cases must be based ultimately on the application of the fact-finding tribunal's experience with the mainsprings of human conduct to the totality of the facts of each case. The nontechnical nature of the statutory standard, the close relationship of it to the data of practical human experience, and the multiplicity of relevant factual elements, with their various combinations, creating the necessity of ascribing the proper force to each, confirm us in our conclusion that primary weight in this area must be given to the conclusions of the trier of fact. Baker v. Texas & Pacific R. Co., 359 U.S. 227 , 79 S.Ct. 664, 3 L.Ed.2d 756; Commissioner v. Heininger, 320 U.S. 467, 475 , 64 S. Ct. 249, 254, 88 L.Ed. 171; United States v. Yellow Cab Co., 338 U.S. 338, 341 , 70 S.Ct. 177, 179, 94 L.Ed. 150; Bogardus v. Commissioner, supra 302 U.S. 34 at 45 , 58 S.Ct. at page 66 (dissenting opinion)."