- 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...)
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