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By way of illustration, petitioner wrote the word "loan" on the
check register and the check stub, respectively, for the two
$50,000 checks she issued to Stephen during 1982 and on the check
stub for the $100,000 check she issued to Robert during that
year. Petitioner sent those check records to PKF, and PKF re-
corded the transfers to Stephen and Robert in petitioner's gener-
al ledger in accounts labeled "Notes Receivable--S. Miller" and
"Note Receivable--B. Miller", respectively. In addition, on
December 31, 1982, and on December 31, 1983, PKF recorded a
$15,000 credit and a $10,000 credit, respectively, to the "Notes
Receivable--S. Miller" account in petitioner's general ledger.
Those entries correspond to the $15,000 payment that Stephen made
to petitioner on November 29, 1982, and the $10,000 total of the
$5,000 amount forgiven that was stated in each of the forgiveness
letters to Stephen dated December 20, 1982, and August 5, 1983.
On December 31, 1983, PKF also recorded a $10,000 credit to the
"Note Receivable--B. Miller" account in petitioner's general
ledger. That entry corresponds to the $10,000 amount forgiven
that was stated in the unsigned forgiveness letter to Robert.
Petitioner's designation as to the character of the trans-
fers at issue and any other actions relating to those transfers
is not necessarily indicative of their substance. See Alterman
Foods, Inc. v. United States, 505 F.2d 873, 877 (5th Cir. 1974).
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