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proportion. As stated previously, Ms. Friedeberg did credibly
testify that she provided regular and substantial services in
respect to the rental properties including Valencia and South
Fitch. On Form 706, petitioner reported section 2040
contribution credits related to Valencia and South Fitch of 21.13
percent and 21.61 percent, respectively. Because petitioner has
not provided us with sufficient evidence in order to make a
specific allocation of Ms. Friedeberg's services amongst the
properties to which the services relate, we find the percentages
listed on the initial Form 706 to be probative in making a
reasonable allocation of the value of Ms. Friedeberg's services.
Using our best judgment under these circumstances, we hold that
petitioner is entitled to section 2040 contribution credits for
Valencia and South Fitch of 21.13 percent and 21.61 percent,
respectively. Cohan v. Commissioner, supra.
However, petitioner has not offered any evidence which would
persuade us that Ms. Friedeberg performed substantial services in
connection with the Laidley or Acadia properties. Petitioner
reported no contribution credits on Form 706 for the Laidley and
Acadia properties. Although Ms. Friedeberg testified that she
regularly cleaned Laidley, she also resided in Laidley with
decedent for all the years in which she and decedent lived
together. Laidley was never used as a rental property. Also,
decedent did not receive any rental income from Acadia subsequent
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