On June 1, 2020, the Tax Court issued a Memorandum Opinion in the case of Estate of Bolles v. Commissioner (T.C. Memo. 2020-71). The sole issue before the court in Estate of Bolles v. Commissioner was whether the transfers from the decedent, Mary Bolles, to her son Peter, which transfers aggregated over $1m, should be treated as loans or gifts. According to the Tax Court, “Each side sees the answer as totally one way. We disagree