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consideration equal to at least one-half of the total
consideration that decedent and his spouse paid for the three
parcels of real property. If so, one-half of the value of the
three properties is excluded from decedent's estate under section
2040. Ann Van Tine performed valuable services for her father's
construction business from 1955 to the 1970's, but the record
does not show how much consideration decedent and his wife paid
to buy and improve the three parcels. As a result, we have no
basis to decide what part of the parcels' value that is
attributable to Ann Van Tine's services. Thus, on this record,
we hold for respondent.
Section references are to the Internal Revenue Code. Rule
references are to the Tax Court Rules of Practice and Procedure.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
A. The Van Tines
Ann Van Tine was born around 1937. She was the only child
of decedent and Betty Van Tine. Ann Van Tine lived at home with
her parents until 1980 when she was about 43. Her parents owned
and operated Van Tine Construction (VTC), which built homes and
commercial buildings. They paid for all of her basic personal
needs, such as food and clothing. They bought and insured her
vehicle. Ann Van Tine never attended college, married, or had
children. Her hobbies were growing bonsai trees and keeping
German Shepherd dogs.
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