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proof is on petitioners to show that the transaction at issue was
a bona fide loan. Rule 142(a); Welch v. Helvering, 290 U.S. 111,
115 (1933). We always examine intrafamily transactions with
special scrutiny. Caligiuri v. Commissioner, 549 F.2d 1155, 1157
(8th Cir. 1977), affg. T.C. Memo. 1975-319; Perry v.
Commissioner, 92 T.C. 470, 481 (1989), affd. without published
opinion 912 F.2d 1466 (5th Cir. 1990); Bragg v. Commissioner,
T.C. Memo. 1993-479. The presumption is that a transfer between
family members is a gift. Perry v. Commissioner, supra at 481;
Estate of Reynolds v. Commissioner, 55 T.C. 172, 201 (1970).
This presumption may be rebutted by an affirmative showing that
there existed a real expectation of repayment and intent to
enforce the collection of the indebtedness. Estate of Van Anda
v. Commissioner, 12 T.C. 1158, 1162 (1949), affd. per curiam 192
F.2d 391 (2d Cir. 1951). A mere declaration of intent by the
taxpayer is insufficient if the transaction fails to exhibit more
reliable indicia of debt. See Williams v. Commissioner, 627 F.2d
1032, 1034 (10th Cir. 1980), affg. T.C. Memo. 1978-306; Alterman
Foods, Inc. v. United States, 505 F.2d 873, 877 (5th Cir. 1974).
The determination of whether a transfer was made with a real
expectation of repayment and an intention to enforce the debt
depends on all the facts and circumstances including whether: (1)
There was a promissory note or other evidence of indebtedness;
(2) interest was charged; (3) there was a fixed schedule for
repayment; (4) security or collateral was requested; (5) a demand
for repayment was made; (6) the parties' records, if any, reflect
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