- 13 - Mortgage Loan Percent Claimed Item No. Description Balance Included Balance 1 Dolores $79,387 53.67 $42,607 2 Onondaga 127,756 55.32 70,969 In the notice of deficiency, respondent determined that decedent's estate was entitled to deduct one-half of the date-of- death balances of the mortgages related to the Dolores and Onondaga properties. OPINION Section 2040 Contribution Credits We must first decide whether the estate is entitled to contribution credits pursuant to section 2040 regarding the value of the real properties, bank accounts, and certificates of deposit that were held in the joint names of decedent and Ms. Friedeberg on the date of decedent's death. In the notice of deficiency, respondent denied the section 2040 contribution credits claimed by decedent's estate and required the estate to include 100 percent of the fair market value of the assets held in joint tenancy with Ms. Friedeberg.Page: Previous 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 Next
Last modified: May 25, 2011