© 2012 GOULD’S, ALL RIGHTS RESERVED.81. CORRECT ANSWER: D.A promise to make a gift is a gratuitous promise, and lacks consideration. Giftsdo not constitute valuable consideration because there is no bargained forexchange, and the promisor gets nothing in return for their promise to act. In thissituation, Homeowner pushed a wheelbarrow out of appreciation for the workLandowner had already performed, and therefore Homeowner’s work was a gift,lacking consideration. Further, a promise to make a gift is a gratuitous promise,and lacks consideration. It appears as though Landscaper promised to make givetickets to Homeowner in consideration of the work that Homeowner hadperformed.However, consideration must relate to future performance, not priorperformance. In effect, Landscaper made a promise to give a gift to Homeowner,and Landscaper later reneged on his promise, by failing to give the tickets toHomeowner.Therefore, Homeowner’s will lose, because his work was notsufficientconsiderationforLandscaper’spromisetogiveHomeownerthebaseball tickets.