A transfer from A to B in consideration for a service to be rendered by B to C may constitute a gift from A to C, or both to B and C, depending on whether the service to be rendered is or is not adequate and full consideration in money or money's worth for that which is received by B.
NOTE: Reference: Section 15104, Revenue and Taxation Code.
Cal. Code Regs. Tit. 18, § 15104.11