Four years ago, D, who then had a net worth of $100,000, guaranteed a bank loan for a friend, A, for $100,000. This year A defaulted on the loan, the bank obtained a judgment against Dand the bank levied on D's assets. The levy yielded only $40,000. When, if at all, did D make a gift? And in what amount? Consider Bradford V Commissioner, 34 T.C. 1059 (1960), and Treasury Regulations section 25.2511-1 and 25.2512.8. CF. Abrams v. united states, 1988-1 U.S.T.C. (CCH) 13,769 (S.D.N.Y. 1998) (discharge of lien).