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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...)
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