- 29 -
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
Page: Previous 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 NextLast modified: May 25, 2011