- 15 - She also reported that she was a medical assistant from 1970 to 1986 and a business manager or business consultant from 1988 to 1995. On her 1970, 1971, and 1972 returns, Ann Van Tine deducted 12,000 miles of automobile expenses in connection with her work for Ebaugh. OPINION A. Background A decedent's estate includes the date-of-death value of property he or she owns jointly, except for any part of the value that the estate shows is attributable to consideration provided by the surviving joint tenant. Sec. 2040(a);3 sec. 20.2040-1, 3 Sec. 2040(a) provides in part: (a) General Rule.--The value of the gross estate shall include the value of all property to the extent of the interest therein held as joint tenants with right of survivorship by the decedent and any other person, * * * except such part thereof as may be shown to have originally belonged to such other person and never to have been received or acquired by the latter from the decedent for less than an adequate and full consideration in money or money's worth: Provided, That where such property or any part thereof, or part of the consideration with which such property was acquired, is shown to have been at any time acquired by such other person from the decedent for less than an adequate and full consideration in money or money's worth, there shall be excepted only such part of the value of such (continued...)Page: Previous 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 Next
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