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is no indication in the record that petitioner would have re-
quired him to sell or refinance his house for that purpose.
It is also significant that the gross income reported by
Stephen and his wife in their joint Federal income tax returns
for the years 1982 through 1985 ranged from approximately $64,000
to $73,000. Stephen testified that his income was to be the
source of repayment. However, the record does not establish that
Stephen's income during the years 1982 through 1985 was suffi-
cient not only to cover all his personal living expenses, his
other expenses, and his income tax liabilities, but also to
permit him to accumulate sufficient assets to repay no later than
September 14, 1985, the $100,000 petitioner transferred to him in
1982.
On the record before us, petitioners have failed to estab-
lish that at the time in 1982 when petitioner transferred
$100,000 to Stephen she reasonably believed that he would be able
to repay that amount on demand or on September 14, 1985, if peti-
tioner made no demand prior to that date. See, e.g., Zimmerman
v. United States, 318 F.2d at 613.
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