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Shepherd dogs, landscaping, selling real estate, and working for
Ebaugh. We disagree; the time she spent with those activities
did not preclude her from working a substantial amount of time
for VTC before 1980.
4. Conclusion
We conclude that Ann Van Tine performed a substantial
service for VTC over the years. However, that conclusion is not
enough for petitioner to prevail for reasons discussed next.
C. Whether Petitioner Has Shown That Ann Van Tine Furnished
Consideration as Required by Section 20.2040-1(a), Estate
Tax Regs.
1. Whether Petitioner Has Shown How Much Ann Van Tine's
Parents Paid To Buy and Improve the Three Properties
To exclude an amount from decedent's estate under section
2040(a), petitioner must show, among other things, the total
consideration paid to acquire and improve the three properties.
Sec. 2040(a); Estate of Young v. Commissioner, 110 T.C. at 314;
sec. 20.2040-1(a), Estate Tax Regs. Ann Van Tine's parents
bought the 7 Diamonte Lane property in 1962. They bought the
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