- 27 - worked as a team for 30 years to acquire the property at issue in that case. Income from their property belonged to both of them under Indiana law. Although we could not trace each transaction, we held that the taxpayer qualified under section 2040. Here, we do not know how much consideration decedent paid to buy and improve the three properties. D. Conclusion Ann Van Tine provided a substantial service to VTC. However, she has not shown what part of the value of the three properties at issue is attributable to the amount of consideration that she furnished with those services.7 Thus, 7 In light of our conclusion, we need not decide respondent's contentions that Ann Van Tine's services were not adequate consideration for the joint tenancy interests at issue because: (1) Decedent used the transfers into joint tenancy to avoid probate; (2) Ann Van Tine would have inherited her parents' property under any circumstances; (3) Ann Van Tine did not report her receipt of interests in the properties as income on her individual income tax returns; (4) Ann Van Tine took a full step- up in basis for 7 Diamonte Lane and one of the Sepulveda Blvd. properties; (5) the handwritten statements on the joint tenancy deeds said that Ann Van Tine's father made the conveyances for no consideration; and (6) there was no agreement between Ann Van (continued...)Page: 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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