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what extent, a fractional interest discount or lack of
marketability discount should be applied to a decedent's property
held in joint tenancy with right of survivorship. In Estate of
Young v. Commissioner, supra at 315-316, we stated:
Under the scheme of section 2040(a), the amount
includable in a decedent's gross estate does not depend
on a valuation of property rights actually transferred
at death, or on a valuation of the actual interest held
by the decedent (legal title); instead, decedent's
gross estate includes the entire value of property held
in a joint tenancy by him and any other person, except
to the extent the consideration for the property was
furnished by such other person. * * * Section 2040(a)
provides an artificial inclusion of the joint tenancy
property: the entire value of the property less any
contribution by the surviving joint tenant. Except for
the statutory exclusions in section 2040(a), there is
no further allowance to account for the fact that less
than the entire interest is being included. [Citation
and fn. ref. omitted.]
Applying the same reasoning to the instant case, we conclude that
petitioner is not entitled to fractional interest discounts on
any of the properties based on joint ownership with Ms.
Friedeberg.
Section 2053 Deductions for Unpaid Mortgages
On Schedule K of Form 706, petitioner claimed deductions
related to mortgages on the Dolores and Onondaga properties of
$42,607 and $70,969, respectively. Petitioner allocated the
mortgages on the properties in amounts equal to the section 2040
inclusion percentages of 53.67 for the Dolores property and 55.32
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