Estate of Max L. Van Tine, Deceased, Ann Van Tine, Executor - Page 23

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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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