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$29,177.53 from the estate of Lucian Lubinski. With respect to
the jointly acquired real properties, Ms. Friedeberg testified
that the downpayments for Chenery, Dolores, and Onondaga were all
paid with funds from bank accounts held in the joint names of
decedent and Ms. Friedeberg. The downpayments for the Chenery,
Dolores, and Onondaga properties were in the amounts of
$31,841.50, $59,514.98, and $47,817.16, respectively, and totaled
$139,173.64. The purchases of Chenery, Dolores, and Onondaga
were all completed during the years 1983 through 1985. From 1974
to 1985, Ms. Friedeberg has shown that she received at least
$71,862.8 One-half of the total downpayments for the properties
would require a contribution of $69,586.82.9 We find Ms.
Friedeberg to be a credible witness, and we accept the veracity
of her testimony. Thus, notwithstanding the fact that Ms.
Friedeberg was unable to provide every receipt for each bank
deposit, purchase of a CD, and receipts for each reinvestment
into another CD, it is reasonable to conclude that she
contributed one-half toward the total purchase prices of the
Chenery, Dolores, and Onondaga properties. Cohan v.
Commissioner, supra.
8This amount includes $15,000 from Ms. Friedeberg's divorce,
a $4,000 contribution, $10,000 from the CD purchased with German
restitution funds, $29,177 from the estate of Lucian Lubinski,
and $13,685 from the estate of Hirtha Gray.
9One-half of $139,173.64 equals $69,586.82.
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