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Decedent forgave a debt owed by her daughter, a family member.
No consideration was given for the cancellation. "The
presumption is that a transfer between closely related parties is
a gift." Estate of Reynolds v. Commissioner, 55 T.C. 172, 201
(1970). Respondent has met her burden of proof on this issue,
and petitioner has offered no evidence, only conjecture, to
counter such a finding. We hold that the cancellation of the
debt is a taxable gift from decedent to her daughter.
To reflect the foregoing,
Decision will be entered
under Rule 155.
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