There is no Paypal seller protection for a transaction that is characterized as a non-commercial transfer, nor should there be. Here's an idea that I follow: don't use the non-commercial settings on Paypal to cheat the company out of its fees. I do not sell items with gift payment nor will I buy with them that way [I add 3% to the price if the seller wants gift]. Setting aside the ethics of your actions--at the root of it all, you lied to Paypal about the transaction in order to scam them out of the transfer fees--if something goes wrong, you have no recourse because you misrepresented the transaction as a non-commercial one.
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