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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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