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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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