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accumulate sufficient assets to repay no later than October 4,
1985, the $100,000 petitioner transferred to him in 1982. In
fact, although Robert testified that he believed at the time
petitioner transferred $100,000 to him that he was obligated to
repay that entire amount by October 4, 1985, he also testified
that he probably would not have repaid that entire amount by that
date.12
On the record before us, petitioners have failed to estab-
lish that at the time in 1982 when petitioner transferred
$100,000 to Robert she reasonably believed that he would be able
to repay that amount on demand or on October 4, 1985, if
petitioner made no demand prior to that date. See, e.g.,
Zimmerman v. United States, supra at 613.
8. Whether Any Records of Petitioner and/or Her Sons
Reflected Each of the Transfers at Issue as a Loan
Certain records relating to the transfers at issue that were
maintained by petitioner or on petitioner's behalf are, or are in
part, consistent with petitioners' position in these cases that
those transfers were loans that petitioner forgave over the
period 1982 through 1990 and with other evidence in the record.
12 Robert further testified that while he would have been able
to repay by Oct. 4, 1985, a substantial portion of the $100,000
petitioner transferred to him, he believed he could have obtained
an extension of time from her within which to repay the remainder
of that amount.
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