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made. In other words, pursuant to the terms of that note, if
petitioner did not demand payment from Robert prior to October 4,
1985, he was to pay her the principal amount in all events on
that date. (Hereinafter, the date of October 4, 1985, that was
stated in the October 1982 note will sometimes be referred to as
the due date of that note.)
Petitioner wanted to treat both her sons Stephen and Robert
in the same or essentially the same manner. Thus, the terms of
the October 1982 note signed by Robert were very similar to the
terms of the September 1982 note signed by Stephen. At the time
Robert signed the October 1982 note, there was no discussion
between petitioner and Robert as to what, if any, consequences
would result in the event he did not make the payment required by
the terms of the note, and he did not expect to repay the entire
principal amount of $100,000 by October 4, 1985.
Petitioner did not make a written or oral request of Robert
to repay the October 1982 note on or after October 4, 1985.
Petitioner and Robert had no discussions on or after the due date
of the October 1982 note with respect to a possible extension of
the time within which he was to pay off that note or as to any
other matter relating to that note.
Robert made no payments to petitioner with respect to the
October 1982 note during the three-year period following the date
on which he signed that note. Nor did he repay that note on or
after October 4, 1985, the date on which it was in all events
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