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compensation shall be paid to * * * [Bell], for such care,
attention and services as she shall be able to render to my said
daughter” (the compensation provision). Decedent’s daughter
predeceased him, so the compensation provision in question never
came into effect. We attach very little weight to the
compensation provision. Decedent’s daughter was not Bell’s
daughter. Bell may very well have felt affection for her.
Nevertheless, Bell was not a wealthy woman. Decedent was
wealthy, and his providing for compensation to be paid to Bell to
encourage her to look after his daughter is natural. It tells us
very little about decedent’s view of his relationship with Bell
so long as he lived.
D. The Ledgers
Apparently, the ledgers record all of the Bell payments.
Several of the Bell payment entries are annotated "Sal".
Petitioners contend that the term "Sal" is an abbreviation for
the word "salary". Petitioners argue that the monthly pattern of
these transfers and the identification of some of the transfers
as "Sal" shows that the checks were payment for services.
While petitioners may have exposed an ambiguity in some of
the Bell payments, no dispositive evidence was presented that
proves the checks were not gifts. We have found that Bell and
decedent had a close, personal, and loving relationship,
resembling a marriage. We are unpersuaded by any of the
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