- 23 - 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 thePage: Previous 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Next
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