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petitioner may not exclude one-half of the value of the three
properties at issue.8
To reflect the foregoing,
Decision will be
entered for respondent.
7(...continued)
Tine and her parents that Ann Van Tine would work for VTC without
pay until her parents retired in exchange for a joint tenancy
interest in whatever property Ann Van Tine's parents owned at
that time. We also need not decide respondent's contention that
we must subtract the value of the services the Van Tines provided
to Ann Van Tine from the total value of Ann Van Tine's services
to VTC to calculate the net value of services that she provided
for purposes of section 2040(a).
8 The Court recently applied Cohan v. Commissioner, 39 F.2d
540 (2d Cir. 1930), to decide the value of services contributed
by a joint tenant. See Estate of Fratini v. Commissioner, T.C.
Memo. 1998-308. Even if we did that here, we could not apply the
mathematical formula stated in Estate of Young v. Commissioner,
110 T.C. 297, 315 (1998), to calculate the amount excluded
because we do not know the cost to buy and improve the three
properties at issue.
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