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decedent, the property thereafter produces income, and the income
is used as consideration for the acquisition of the jointly held
property, the income from the time of receipt of the gift has
been held to be the surviving joint tenant's income. Estate of
Goldsborough v. Commissioner, 70 T.C. 1077, 1083 (1978), affd.
without published opinion 673 F.2d 1310 (4th Cir. 1982); see also
Harvey v. United States, supra; Estate of Howard v. Commissioner,
supra.
As we previously stated, the Dolores, Chenery, and Onondaga
properties were jointly purchased and owned equally by decedent
and Ms. Friedeberg. On or about December 10, 1987, decedent
transferred an undivided one-half joint tenancy interest in each
of the remaining properties including Laidley, Valencia, South
Fitch, and Acadia to Ms. Friedeberg. From 1988 through 1991,
decedent and Ms. Friedeberg reported $325,831.6711 of net rental
income from all the jointly held properties.
Ms. Friedeberg testified that amounts received through
rental of the properties were equally shared and deposited in the
11Net profits from rentals were reported as follows:
Year Amount
1988 $46,406.49
1989 68,744.73
1990 89,085.41
1991 121,595.04
Total $325,831.67
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