- 8 - gift tax, after taking account of the annual exclusion provided by section 2503(b) and the gift-splitting provisions of section 2513(a)(1). In an undated letter that petitioner wrote to Stephen, and that Stephen signed on February 6, 1987 (February 1987 letter to Stephen), petitioner summarized the amounts that she considered paid as of January 3, 1986, with respect to the $50,000 check that she had issued to him on June 18, 1982, as follows:9 Aug. 5, 1983 $2,500 Jan. 22, 1984 7,500 Mar. 31, 1985 7,500 Jan. 3, 1986 7,500 Petitioner made no reference in the February 1987 letter to Stephen to the $50,000 check that she had issued to him on September 9, 1982. Petitioner omitted from that letter the $5,000 amount forgiven that was stated in her forgiveness letter dated December 20, 1982. Nor did that letter refer to any portion of the $15,000 payment that Stephen had made to her on November 29, 1982. Stephen reviewed that letter prior to signing it. However, he did not notice, or question the reasons for, those omissions. PKF recorded a $15,000 credit and a $10,000 credit to the "Notes Receivable--S. Miller" account in petitioner's general 9 In determining the amounts petitioner considered paid by Stephen as of Jan. 3, 1986, she applied one-half of each amount forgiven that was stated in each of the forgiveness letters for the years 1983, 1984, 1985, and 1986 to the $50,000 check that she had issued to him on June 18, 1982.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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