Yes she has gross income. Cesarini says found property results in immediate gross income. Distinguished from bargain purchase property. Sam finding the ring satisfies all 3 factors of GG. None. Sam was taxed for it in 2018. Her basis in the ring is 5k. Tax cost = basis rule. S1.61(2)(d)(2) Yes. GI of 2500. Basis protects you up to how much you paid taxes for.