Estate of Wayne-Chi Young, Deceased, Tsai-Hsiu Hsu Yang, Executrix - Page 27

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          Federal estate tax was part of the Revenue Act of 1916, ch. 463,            
          39 Stat. 756; the act's main purpose was to raise revenue.  Since           
          its origin in 1916, the provision including joint tenancy in the            
          gross estate, now incorporated in section 2040(a), has remained             
          substantially unchanged.12                                                  

               11(...continued)                                                       
               than an adequate and full consideration in money or money's            
               worth, there shall be excepted only such part of the value             
               of such property as is proportionate to the consideration              
               furnished by such other person: Provided further, That where           
               any property has been acquired by gift, bequest, devise, or            
               inheritance, as a tenancy by the entirety by the decedent              
               and spouse, then to the extent of one-half of the value                
               thereof, or, where so acquired by the decedent and any other           
               person as joint tenants with right of survivorship and their           
               interests are not otherwise specified or fixed by law, then            
               to the extent of the value of a fractional part to be                  
               determined by dividing the value of the property by the                
               number of joints tenants with right of survivorship.                   
               12  In 1919, sec. 202(c) was renumbered sec. 402(d), and the           
          second paragraph dealing with stock in a domestic corporation was           
          deleted.  In the Revenue Act of 1921, ch. 134, sec. 402(d), 42              
          Stat. 227, 278, sec. 402(d) read as follows:                                
               SEC. 402(d).  To the extent of the interest therein held               
               jointly or as tenants in the entirety by the decedent and              
               any other person, or deposited in banks or other                       
               institutions in their joint names and payable to either or             
               the survivor, except such part thereof as may be shown to              
               have originally belonged to such other person and never to             
               have been received or acquired by the latter from the                  
               decedent for less than a fair consideration in money or                
               money's worth: Provided, That where such property or any               
               part thereof, or part of the consideration with which such             
               property was acquired, is shown to have been at any time               
               acquired by such other person from the decedent for less               
               than a fair consideration in money or money's worth, there             
               shall be excepted only such part of the value of such                  
               property as is proportionate to the consideration furnished            
               by such other person: Provided, further, That where any                
                                                             (continued...)           




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