Elizabeth B. Miller - Page 9

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          ledger on December 31, 1982, and on December 31, 1983, respec-              
          tively.  No other credit entries were made to that account during           
          the period 1982 through 1989.                                               
               Petitioner filed a Federal gift tax return for 1982 that was           
          prepared by PKF.  That return did not reflect as a gift to                  
          Stephen the $5,000 amount forgiven that was stated in the for-              
          giveness letter to him dated December 20, 1982.  Petitioner did             
          not file Federal gift tax returns for the years 1983 through                
          1986.  Petitioner filed Federal gift tax returns for the years              
          1987 through 1990.  Petitioner's 1987 Federal gift tax return               
          showed a $20,000 gift to Stephen as a result of forgiveness of              
          indebtedness, while her forgiveness letter to him for that year             
          stated that the amount forgiven was $5,000.  Petitioner's 1988              
          Federal gift tax return showed a cash gift of $20,000 to Stephen            
          and no gift as a result of forgiveness of indebtedness, while her           
          forgiveness letter to him for that year stated that the amount              
          forgiven was $20,000.  Petitioner's 1989 Federal gift tax return            
          showed a $20,000 gift to Stephen as a result of forgiveness of              
          indebtedness, but petitioner sent no forgiveness letter to him              
          during that year.                                                           
          Petitioner's Transfer to Robert                                             
               On October 4, 1982, petitioner gave a check in the amount of           
          $100,000 to her son Robert.  Petitioner wrote the word "loan" on            
          the check stub for that check, and she sent that check stub to              
          PKF.  Because petitioner had written the word "loan" on that                



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