- 17 - 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.Page: Previous 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 Next
Last modified: May 25, 2011