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gave his grandchildren 600 and 400 shares of Price Co. stock,
respectively. The letters also stated that those grandchildren
who had borrowed stock would have their loan decreased by those
amounts. In addition, petitioners introduced a letter prepared
by Drachman from Christmas 1991 indicating that their loan would
be forgiven in the amount of 300 shares of Price Co. stock.
Petitioner testified that Drachman treated all of his
grandchildren equally. Since petitioners, however, received far
more shares of stock, and at a different time than provided in
the Christmas letters, they argue, the additional stock must have
been a loan.
Petitioner testified that:
[Mrs. Vinikoor's] father and mother were married and
divorced twice and [Mrs. Vinikoor] was the youngest of
the [children] and so she incurred a lot of emotional
animosity towards her father and so she was
independent, * * * she was supporting herself and
paying for her college and wedding and all that stuff,
where I don't think that the others were.
Contrary to petitioners' position, this information makes the
additional shares transferred to petitioners from Drachman appear
more gift-like in nature. Drachman had a propensity for giving
stock, and we presume he loved his granddaughter. Mrs. Vinikoor
was estranged from her father and incurred greater expenses than
the other grandchildren. We infer from this that the additional
shares represented a wedding gift, a gift of college tuition
payments, a graduation gift, or simply a gift to a grandchild who
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