- 12 -
payable. Even though Robert failed to repay the October 1982
note on its due date, petitioner never instituted legal proceed-
ings or took other steps to enforce repayment.
Rather than requesting Robert to pay off the October 1982
note, at or near the various dates set forth below, petitioner
wrote and delivered a letter (forgiveness letter) to him in which
she stated that, as of the date of the letter, she was "reducing
the principal balance" of the October 1982 note by the amount
stated in the letter. The date of each forgiveness letter to
Robert and the reduction of the "principal balance" (amount for-
given) stated in each such letter was as follows:
Amount
Date of Letter Forgiven
Jan. 22, 1984 $15,000
Mar. 31, 1985 15,000
Jan. 3, 1986 15,000
Feb. 9, 1987 15,000
Jan. 6, 1988 20,000
June 16, 1989 20,000
Total 100,000
In addition, in an unsigned letter to Robert dated April 9,
1983 (unsigned forgiveness letter to Robert), petitioner stated
that, as a part of her 1982 annual gift to Robert, she was
"reducing the principal balance" of the October 1982 note by
$10,000 ($10,000 amount forgiven).
Petitioner determined the amount forgiven that was stated in
each of the forgiveness letters to Robert and the $10,000 amount
forgiven that was stated in the unsigned forgiveness letter to
Page: Previous 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 NextLast modified: May 25, 2011