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in decedent's estate. Petitioner argues that Ms. Friedeberg
contributed her separate funds to jointly held bank accounts and
thereafter, decedent and Ms. Friedeberg invested in various money
market securities and real properties in which they sought to
maximize income and acquire additional real property.
Section 2040 creates a rebuttable presumption that the
value of the entire property is includable in the deceased joint
tenant's estate, and the burden of showing original ownership or
contribution to the purchase price by the surviving joint tenant
falls upon the estate. Hahn v. Commissioner, supra at 144;
Estate of Heidt v. Commissioner, 8 T.C. 969 (1947), affd. per
curiam 170 F.2d 1021 (9th Cir. 1948); sec. 20.2040-1(a)(2),
Estate Tax Regs. Where evidence indicates that the surviving
joint tenant did contribute money or money's worth under section
2040, courts have held that the executor's burden has been met
notwithstanding that the exact amount of the contribution could
not be proven by the taxpayer. Estate of Carpousis v.
Commissioner, T.C. Memo. 1974-258; Estate of Selecman v.
Commissioner, a Memorandum Opinion of this Court dated Nov. 6,
1950. In those circumstances, we have applied the rule
enunciated in Cohan v. Commissioner, 39 F.2d 540 (2d Cir. 1930),
and allowed taxpayers to approximate where amounts were not
definitely determinable. See, e.g., Estate of Carpousis v.
Commissioner, supra; Estate of Selecman v. Commissioner, supra.
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