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2255 Sepulveda Boulevard property in 1963 and built an office
building on it in 1964. Decedent and Moore bought the 2243-45
Sepulveda Boulevard property in 1973. However, the record does
not show how much Ann Van Tine's parents paid to buy and improve
the three properties.6
2. Petitioner's Contentions
Petitioner contends that it needs to show only that Ann Van
Tine's services were more than minimal or part time. Petitioner
contends that we stated this standard in Estate of Anderson v.
Commissioner, T.C. Memo. 1989-643, in which we applied section
2040 and section 20.2040-1, Estate Tax Regs. We disagree. In
that case, the decedent gave her son a joint interest in
property. The decedent and her former husband paid $37,000 in
1955 to buy the property. Estate of Anderson differs from this
6 On her 1993 income tax return, Ann Van Tine reported that
her basis for purposes of depreciation was $377,334 for 7
Diamonte Lane and $123,392 for each Sepulveda Blvd. property for
a total of $624,118. Petitioner does not contend that we can
derive decedent's total cost to acquire and improve the
properties from this return.
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