Elizabeth B. Miller - Page 7

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          September 1982 note.  Stephen did not make an offer of repayment            
          or an actual repayment of the September 1982 note on or after               
          September 14, 1985, the date on which it was in all events pay-             
          able.  Even though Stephen failed to pay off the September 1982             
          note on its due date, petitioner never instituted legal proceed-            
          ings or took other steps to enforce repayment.                              
               Rather than requesting Stephen to pay off the September                
          1982 note, at or near the various dates set forth below, peti-              
          tioner wrote and delivered a letter (forgiveness letter) to him             
          in which she stated that, as of the date of the letter, she was             
          "reducing the principal balance" of the September 1982 note by              
          the amount stated in the letter.  The date of each forgiveness              
          letter to Stephen and the reduction of the "principal balance"              
          (amount forgiven) stated in each such letter was as follows:                
                                                 Amount                               
                             Date of Letter          Forgiven                         
                            Dec. 20, 1982       $5,000                                
                            Aug.  5, 1983       5,000                                 
                            Jan. 22, 1984       15,000                                
                            Mar. 31, 1985       15,000                                
                            Jan.  3, 1986       15,000                                
                            Feb.  9, 1987        5,000                                
                            Jan.  6, 1988       20,000                                
                            Jan.  3, 1990        5,000                                
                            Total               85,000                                
               Petitioner determined the amount forgiven that was stated in           
          each of the forgiveness letters to Stephen by reference to the              
          total amount that petitioner and her husband were permitted to              
          give him in a particular year without the imposition of Federal             




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