- 9 - 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 thatPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011