Elizabeth B. Miller - Page 29

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          Nor do PKF's entries in petitioner's general ledger lend credence           
          to petitioner's contention that the transfers at issue were loans           
          that petitioner forgave over the period 1982 through 1990.  Those           
          entries merely reflected the labels that petitioner placed on               
          those transfers and related actions and were not based on any               
          independent research conducted by PKF to ascertain whether the              
          substance of such transfers and actions was consistent with                 
          petitioner's characterization of them.                                      
               It is also significant that the general ledger maintained              
          for petitioner by PKF is in part inconsistent with petitioner's             
          position here and with other evidence in the record.  No other              
          credit entries were recorded in the accounts in petitioner's                
          general ledger labeled "Notes Receivable--S. Miller" and "Note              
          Receivable--B. Miller".  Yet the record herein contains forgive-            
          ness letters to Stephen and to Robert, respectively, in which               
          petitioner purports to forgive stated portions of the respective            
          amounts each of them allegedly owed her.                                    
               Other inconsistencies in the evidence relating to the trans-           
          fers at issue cast further doubt on whether those transfers were            
          genuine loans.  By way of illustration, in the February 1987                
          letter to Stephen in which petitioner summarized the amounts that           
          she considered paid as of January 3, 1986, with respect to the              
          $50,000 transfer she had made to him on June 18, 1982, petitioner           







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