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the part of the date-of-death value of the property which the
consideration furnished by the survivor bears to the total cost
of acquisition and capital additions. Sec. 2040(a); Estate of
Young v. Commissioner, 110 T.C. 297, 314 (1998); sec.
20.2040-1(a), Estate Tax Regs. This can be expressed
mathematically (mathematical formula) as follows:
Value of the property1 Consideration furnishedAmount
on the date of death orX by the survivor = excluded
alternate valuation date Total consideration paid to
acquire and improve the
property
1The parties agree that the entire value of the properties at issue on the
date of death is $1,150,000.
Estate of Young v. Commissioner, supra at 315; Estate of
Goldsborough v. Commissioner, 70 T.C. 1077, 1082 (1978), affd.
4(...continued)
is shown not to be attributable to money or
other property acquired by the other joint
owner or owners from the decedent for less
than a full and adequate consideration in
money or money's worth.
The entire value of jointly held property is
included in a decedent's gross estate unless
the executor submits facts sufficient to show
that property was not acquired entirely with
consideration furnished by the decedent, or
was acquired by the decedent and the other
joint owner or owners by gift, bequest,
devise, or inheritance.
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