Jewell E. Gray, Donor, Deceased and Estate of Jewell E. Gray, Deceased, Jewell Mae Detjen, Personal Representative, et al. - Page 18

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          conclude that the parties did not have a fixed repayment                    
          schedule.  This factor favors respondent.                                   
                    h.   Security or Collateral                                       
               Petitioner contends that decedent provided collateral to               
          Beth W. Corp. for the purported loans in the form of a $500,000             
          mortgage on her home, but introduced no convincing evidence to              
          establish that this had happened.  Even if true, this does not              
          establish that decedent gave Beth W. Corp. adequate collateral              
          for the transfers.  This factor favors respondent.                          
                    i.   Existence of a Written Loan Agreement                        
               There was no written loan agreement.  This factor favors               
                    j.   Treatment as Loans in Records                                
               Decedent and Beth W. Corp. recorded and treated the                    
          transfers as loans.  Beth W. Corp. reported interest income and             
          decedent recognized dividends owing to her that she used to repay           
          the loans.  Beth W. Corp. reported the transfers as loans                   
          receivable on its Florida intangible property returns.  This                
          factor favors petitioner.                                                   
                    k.   Repayments                                                   
               Decedent had received but not repaid transfers of $1,724,198           
          when she died.  Beth W. Corp. deemed $103,000 of the notes                  
          satisfied.  This was apparently done by forgoing payments of                
          redemptions and dividends by Beth W. Corp.  This factor favors              

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