Estate of Max L. Van Tine, Deceased, Ann Van Tine, Executor - Page 26

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          joint effort over 43 years established that the wife had                    
          contributed at least one-half of the total cost of the jointly              
          held property.  Berkowitz v. Commissioner, supra at 320-321.  The           
          Court of Appeals for the Third Circuit noted that it was likely             
          that the husband and wife had a profit-sharing agreement, but               
          remanded the case to the Board of Tax Appeals to decide that                
          issue.  Id. at 321.  This case differs from Berkowitz because               
          there is no comparable evidence here that Ann Van Tine and her              
          parents contributed equally to the cost of acquiring and                    
          improving the joint tenancy property or agreed to share profits.            
               In Estate of Otte, we knew the cost of the properties that             
          were at issue.  Some of the costs were $9,000 for 106 acres in              
          1932, $1,600 for 75 acres in 1937, $2,500 for 25 acres in 1940,             
          $6,000 for 60 acres in 1942, $10,000 for 100 acres in 1946, $800            
          for 20 acres in 1947, and $15,500 for 184 acres in 1950.  In                
          1963, the decedent, his wife, and their son paid $60,500 for 335            
          acres.  They partitioned the land; decedent and his wife received           
          120 acres, and the rest went to their son.  The husband and wife            
















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