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released in the separation agreement executed April 23, 1993. In
any event, under the circumstances, there was no reasonable
explanation of the source of funds that petitioner would have
used to lend money to Trupin. We cannot conclude that the
amounts that she received from Trupin were repayments of bona
fide loans. The presumption of section 6015(c)(4)(B)(ii), as
well as the entire record in this case, leads us to conclude that
those transfers made between September 5, 1989, and October 24,
1994, totaling $958,538 were for tax-avoidance purposes and that
the portions of the deficiency for which petitioner is liable
should be increased by the amount of those transfers.
Respondent also argues that other transfers occurring
between January 1, 1986, and September 5, 1989, were made for the
avoidance of tax or payment of tax. To the extent that payments
were made with respect to acquisitions of property outside of the
United States, we agree with respondent. Thus, the purchase of
real property in Tortola, the formation of Blue Lotus, and the
acquisition of Black Lotus, for which Trupin provided a total of
$186,500, appear by the preponderance of the evidence to create
disqualified assets.
With respect to other transfers, however, the purpose is
ambiguous. For example, respondent asserts that transfers to
petitioner and her mother totaling $136,700 between April 21,
1988, and August 7, 1989, the payment of $20,000 toward the
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