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evidence that Beth W. Corp. tried to collect any of the unpaid
amount. This factor favors respondent.
f. The Existence of Notes or Other Evidence of
Indebtedness
Petitioner contends this factor favors petitioner because
Beth W. Corp. prepared promissory notes for decedent. We
disagree.
The parties stipulated to copies of 14 stamped promissory
notes totaling $1,240,245 and one unsigned note in the amount of
$176,423.12. Most of that amount was past due when decedent
died. Beth W. Corp.'s books and records show that decedent paid
$103,000 of the amount due when she died by forgoing payments for
redemptions and dividends. That amount is less than 6 percent of
the amount that petitioner contends decedent owed to Beth W.
Corp.
The parties to the notes do not appear to have treated the
notes with much substance because they largely ignored their
terms. This factor favors respondent.
g. Fixed Repayment Schedule
Petitioner contends that there was a fixed schedule to repay
the transfers because the notes had due dates. We disagree.
Petitioner did not introduce a repayment schedule. Decedent did
not pay the notes when due. When decedent died, $816,000 was due
but unpaid. Some of the notes were payable on demand, but Beth
W. Corp. had not made any demand for payment on those notes. We
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