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and there was no discussion between petitioner and Stephen as to
what, if any, consequences would result in the event he did not
make the payment required by the terms of the note. In fact,
despite Stephen's failure to remit the payment due under the
September 1982 note on its due date, petitioner made no request
of Stephen to repay that amount on or after that date, and they
had no discussions on or after September 14, 1985, with respect
to a possible extension of time within which he was to pay off
that note or as to any other matter relating to that note. See,
e.g., Clark v. Commissioner, supra at 783.
Although the October 1982 note signed by Robert was not part
of the record in these cases, the record establishes that the
terms of that note were very similar to the terms of the
September 1982 note signed by Stephen; that is to say, the
October 1982 note signed by Robert stated that he was to pay
petitioner $100,000 on demand or on October 4, 1985, if no demand
was made. The record further establishes that petitioner wanted
to treat both her sons Stephen and Robert in the same or essen-
tially the same manner. Thus, we infer that petitioner's inten-
tions and expectations with respect to both notes were, or were
virtually, identical; that is to say, we infer that at the time
Robert signed the October 1982 note, petitioner believed that the
date on which he was to pay her the principal amount was open,
she did not consider the October 4, 1985 date stated in that note
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