Morgan Guaranty, 585 F.2d at 995. As the United States Tax Court stated in Peterson Irrevocable Trust # 2 v. Commissioner, 51 T.C.M. 1300 (1986), aff'd, 822 F.2d 1093 (8th Cir. 1987): Whether a taxpayer possesses a right to receive income or gain is, of course, a question of fact, each case turning on its own particular facts.