Estate of Sylvia P. Goldman, Deceased, Marsha Goldberg and Linda Tanenbaum, Co-executrices - Page 16

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            amount.  Respondent, on the other hand, contends that the court                           
            invalidated the transfers entirely.  Even if we were to accept                            
            petitioner's interpretation, Matter of Cohen is distinguishable                           
            from the present case.  In Matter of Cohen, the decedent for over                         
            10 years had annually given $10,000 gifts to her children and                             
            grandchildren.  Petitioner, however, has presented no evidence to                         
            demonstrate such a pattern of inter vivos transfers to family                             
            members.  Therefore, we reject petitioner's argument.                                     
                  Because we have found that no valid gifts were made, the                            
            value of the funds totaling $160,000 was includable in decedent's                         
            gross estate pursuant to section 2033.                                                    
            II.  Includability of the Two $25,000 Checks                                              
                  Respondent determined that the value of funds (i.e.,                                
            $50,000), paid to recipients of two $25,000 checks, was                                   
            includable in decedent's gross estate pursuant to sections 2031                           
            and 2033.  The taxpayer bears the burden of proving that                                  
            respondent's determination is erroneous.  Rule 142(a); Welch v.                           
            Helvering, 290 U.S. 111, 115 (1933).                                                      
                  Marsha wrote one $25,000 check to herself and one to Linda.                         
            Petitioner argues, and Marsha testified, that the checks were                             
            reimbursements for amounts Marsha and Linda expended on                                   
            decedent's behalf, and alternatively, that the transfers                                  
            constituted valid and complete gifts.  Respondent contends that                           
            these transfers were not for reimbursement, and did not                                   
            constitute valid and complete gifts.  Thus, respondent argues,                            

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