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and loss from the rental properties. For the years 1981 through
1992, Ms. Friedeberg reported taxable interest income of
$133,051. With respect to the $133,051 of interest income
reported, approximately $3,440 was earned from accounts titled in
Ms. Friedeberg's name alone.
Form 706, United States Estate (and Generation-Skipping
Transfer) Tax Return, was timely filed for decedent's estate on
September 4, 1993. On Schedule E, Part 2, of the Form 706, 11
items of property, which decedent held in joint tenancy with Ms.
Friedeberg, were reported. With respect to the 11 items,
decedent's estate reported contribution credits under section
2040 and fractional interest discounts on certain of the 11
items. The following table sets forth the amounts reflected on
Schedule E, Jointly Owned Property, of Form 706 with respect to
the value of the interests reported upon the date of death before
the section 2040 credit,4 percentage of property included after
taking section 2040 contribution credits, value after taking
section 2040 contribution credits, fractional interest discounts
claimed, and values included in decedent's gross estate after
fractional discounts taken by decedent's estate:
4Although these amounts were not directly listed on Schedule
E, the amounts were calculated and added to the table as a
mathematical computation, using the value on the return divided
by the fractional discount and divided by the sec. 2040
contribution credit rate.
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