- 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 NextLast modified: May 25, 2011