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right of survivorship by the decedent and any other person,
except such part of the value that is attributable to the amount
of consideration in money or money's worth furnished by the
surviving joint tenant. Sec. 2040(a); sec. 20.2040-1(a), Estate
Tax Regs. In applying that exception, the entire value of
jointly held property is included in a decedent's gross estate
unless the executor submits facts sufficient to show that
property was not acquired entirely with consideration furnished
by the decedent, or was acquired by the decedent and the other
joint owner or owners by gift, bequest, devise, or inheritance.
Wilson v. Commissioner, 56 T.C. 579, 586 (1971); sec.
20.2040-1(a)(2), Estate Tax Regs. If part of the consideration
is found to have been contributed by the surviving joint tenant,
then the part of the value of the property as is proportionate to
such consideration is excluded from the decedent's gross estate.
Sec. 20.2040-1, Estate Tax Regs.
Notwithstanding section 2040(a), section 2040(b) provides
that in the case of any qualified joint interest, the value
included in the gross estate is one-half of the value of the
qualified joint interest. Section 2040(b)(2)(B) defines
qualified joint interest to include property held by the decedent
and the decedent's spouse as joint tenants with right of
survivorship, but only if the decedent and the spouse of the
decedent are the only joint tenants. However, section
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