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Estate Tax Regs.4 The amount excluded from the gross estate is
3(...continued)
property as is proportionate to the consideration
furnished by such other person. * * *
4 Sec. 20.2040-1(a), Estate Tax Regs., provides:
(a) In general. A decedent's gross
estate includes under section 2040 the value
of property held jointly at the time of the
decedent's death by the decedent and another
person or persons with right of survivorship,
as follows:
(1) To the extent that the property was
acquired by the decedent and the other joint
owner or owners by gift, devise, bequest, or
inheritance, the decedent's fractional share
of the property is included.
(2) In all other cases, the entire
value of the property is included except such
part of the entire value as is attributable
to the amount of the consideration in money
or money's worth furnished by the other joint
owner or owners. See section 20.2043-1 with
respect to adequacy of consideration. Such
part of the entire value is that portion of
the entire value of the property at the
decedent's death (or at the alternate
valuation date described in section 2032)
which the consideration in money or money's
worth furnished by the other joint owner or
owners bears to the total cost of acquisition
and capital additions. In determining the
consideration furnished by the other joint
owner or owners, there is taken into account
only that portion of such consideration which
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