Estate of Max L. Van Tine, Deceased, Ann Van Tine, Executor - Page 17

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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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