Estate of Albert Fratini, Deceased, Marion Friedeberg, Personal Representative - Page 13

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          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.                                       











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Last modified: May 25, 2011