Estate of Albert Fratini, Deceased, Marion Friedeberg, Personal Representative - Page 26

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          jointly owned bank accounts and were used regularly to purchase             
          CD's.  For the time period after December 10, 1987, decedent and            
          Ms. Friedeberg, as joint owners of the properties, equally shared           
          the net rentals.  Again, we accept the veracity of Ms.                      
          Friedeberg's testimony and find that the rental income received             
          and deposited into joint accounts constitutes sufficient                    
          consideration such that Ms. Friedeberg acquired a 50-percent                
          ownership interest in the bank accounts and CD deposits as of the           
          date of decedent's death.  Therefore, we hold that petitioner is            
          due a contribution credit pursuant to section 2040 equal to 50              
          percent of the joint bank account holdings in the savings,                  
          checking, and CD accounts.                                                  

          Fractional Interest Discounts                                               

               In determining the amount included in decedent's estate                
          pursuant to section 2040, petitioner reduced the value of                   
          decedent's interest in several of the jointly held real                     
          properties by fractional interest discounts.  Petitioner argues             
          that the reported discounted fair market values of the joint                
          tenancy interests in Laidley, Valencia, South Fitch, Chenery,               
          Dolores, and Onondaga are valid.  In the notice of deficiency,              
          respondent disallowed the claimed fractional discounts.                     
               In our recent opinion in Estate of Young v. Commissioner,              
          110 T.C. 297 (1998), we addressed the issue of whether, and to              

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