Elizabeth B. Miller - Page 14

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          the years 1987 through 1989.  Each of those returns showed a gift           
          to Robert resulting from forgiveness of indebtedness.  Peti-                
          tioner's 1987 Federal gift tax return showed a $20,000 gift to              
          Robert as a result of forgiveness of indebtedness, while her                
          forgiveness letter to him for that year stated that the amount              
          forgiven was $15,000.                                                       
                                       OPINION                                        
               Petitioners bear the burden of proving that respondent's               
          determinations are erroneous.  Rule 142(a); Welch v. Helvering,             
          290 U.S. 111, 115 (1933).                                                   
               Petitioners have attempted to satisfy their burden of proof            
          in these cases through testimonial and documentary evidence.                
          With respect to the testimonial evidence, petitioner testified on           
          her own behalf.  Her self-serving testimony was at times vague,             
          conclusory, internally inconsistent, and contradicted by documen-           
          tary evidence.  Although petitioner maintained throughout her               
          testimony that she intended the transfers at issue to be loans,             
          her recollection of specific matters pertaining to those trans-             
          fers was poor or at best hazy.  In an attempt to corroborate                
          petitioner's testimony, petitioners presented the testimony of              
          their sons Stephen and Robert.  Their respective testimony, which           
          was intended to serve the interests of their parents, also was at           
          times vague, conclusory, internally inconsistent, and/or contra-            
          dicted by documentary evidence.  Under the circumstances present-           
          ed here, we are not required to, and we do not, accept the                  



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