Jewell E. Gray, Donor, Deceased and Estate of Jewell E. Gray, Deceased, Jewell Mae Detjen, Personal Representative, et al. - Page 17

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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                  
               Petitioner contends this factor favors petitioner because              
          Beth W. Corp. prepared promissory notes for decedent.  We                   
               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.                
               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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