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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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