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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
respondent.
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
respondent.
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