-57-
toward a finding of bona fide debt, see Estate of Mixon v. United
States, 464 F.2d 394, 403 (5th Cir. 1972), the mere existence of
a note is not dispositive. The issuance of a demand note may not
be indicative of genuine debt where the note is unsecured,
without a maturity date, and without meaningful repayments. See
Stinnett’s Pontiac Serv., Inc. v. Commissioner, supra at 638.
We give little weight to the fact that the record contains
note 1 and note 2 (collectively, promissory notes). Each of the
promissory notes was a demand note with no fixed maturity date,
no written repayment schedule, no provision requiring periodic
payments of principal or interest, no stated collateral, and no
repayments by decedent during her lifetime. The LRFLP also never
demanded repayment from decedent or otherwise sought during her
lifetime to enforce either note. The facts that a note is due on
demand and that the obligee never demanded payments support a
strong inference that the obligee never intended to compel the
obligor to repay the notes. See id. at 640. Such is especially
so where, as here, only one of the promissory notes was prepared
during decedent’s lifetime despite the fact that numerous
payments had been made on her behalf. Although the payments to
the benefit of decedent may have periodically been recorded as
“loans”, those postings provide little if any support for a
finding of bona fide debt. See Estate of Thompson v.
Commissioner, 382 F.3d at 377 n.16; Roth Steel Tube Co. v.
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