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to be a fixed date on which Robert was in all events to pay her
the principal amount, and she had no intention of demanding
payment on October 4, 1985, or on any other date. The record
establishes that 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. In fact, despite Robert's failure to remit the
amount due under the October 1982 note on its due date, petition-
er made no request of Robert to repay that amount on or after
that date. Nor did they have any discussions on or after October
4, 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, 18 T.C.
at 783.
5. Whether a Demand Was Made for Repayments of the
September 1982 Note and the October 1982 Note
At the time of each of the transfers at issue, there was no
discussion between petitioner and either of her sons regarding
the circumstances that would arise if either son defaulted on the
note each signed. Although each of the notes in question that
was signed by Stephen and Robert, respectively, stated that
petitioner had the right to demand repayment of the principal
balance of each such note throughout a three-year period follow-
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