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Stephen, the forgiveness letter addressed to him dated February
9, 1987, stated an amount forgiven of $5,000, while the Federal
gift tax return filed on behalf of petitioner for 1987 reported a
$20,000 gift to Stephen as a result of forgiveness of indebted-
ness. With respect to Robert, the forgiveness letter addressed
to him dated February 9, 1987, stated an amount forgiven of
$15,000, while the Federal gift tax return filed on behalf of
petitioner for 1987 reported a $20,000 gift to Robert as a result
of forgiveness of indebtedness.
Based on our examination of the entire record in these
cases, we find that petitioners have not established that peti-
tioner entered into a bona fide creditor-debtor relationship with
either of her sons at the time of the transfers at issue. We
further find that petitioners have failed to satisfy their burden
of proving that the transfers at issue constituted loans and not
gifts as determined by respondent. We therefore sustain
respondent's determinations in these cases.
To reflect the foregoing and petitioners' concessions,
Decisions will be entered for
respondent.
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