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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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