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Nice try, but it was payment for services rendered no matter how you try to keep it from quacking. That does not necessarily mean it's taxable income. There's a de minimus exception for this type of thing, which you'll find in IRS Publication 525.

Correct me if I'm wrong, but the de minimus exception appears to only apply to a "product or service." In fact, there's even a specific example in the "De Minimis (Minimal) Benefits" section (page 5) that seems to apply to the gift check case:

Holiday gifts. If your employer gives you a turkey, ham or other item of nominal value at Christmas or other holidays, do not include the value of the gift in your income. However, if your employer gives you cash, a gift certificate, or a similar item that you can easily exchange for cash, you include the value of that gift as extra salary or wages regardless of the amount involved.

I'd guess that similar logic would be applied to non-holiday gifts... 'course, I can't see the IRS coming after someone over a $100 AE gift check... :-)

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