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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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