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Petitioner also argues that Ms. Friedeberg provided services
in the form of management of the rental properties from 1974
until 1992. Petitioner argues that these services constitute
adequate consideration contributed in "money's worth" to the
values of the Laidley, Valencia, South Fitch, and Acadia
properties, such that petitioner is entitled to exclude one-half
of the total value of these properties from decedent's estate
under section 2040(a). Respondent asserts that the services Ms.
Friedeberg performed were minimal and that petitioner has not
established a value for Ms. Friedeberg's services.
Our determination of whether Ms. Friedeberg provided full
and adequate consideration is necessarily one of fact. See
Estate of Heidt v. Commissioner, 8 T.C. at 974; Estate of
Anderson v. Commissioner, T.C. Memo. 1989-643. In determining
the consideration furnished by the surviving joint tenant,
amounts furnished by decedent to the surviving joint tenant for
less than full and adequate consideration are to be ignored.
Estate of Anderson v. Commissioner, supra; sec. 20.2040-1(a)(2),
Estate Tax Regs. If part of the consideration is found to have
been contributed by the surviving joint tenant, then the part of
the value of the property as is proportionate to such
consideration is not included in decedent's gross estate. Sec.
20.2040-1(a)(2), Estate Tax Regs.
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