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be adjusted to take into account the value of decedent's
contribution rights.
2. The Value of Decedent's Contribution Rights Cannot Be
Determined
Of course, it is not always easy to determine the value of
contribution rights. In some cases, we have simply held that
each co-obligor would contribute a proportionate share of the
debt, based on the number of obligors. See, e.g., Estate of
Atkins v. Commissioner, 2 T.C. 332, 346-347 (1943) (decedent was
one of three debtors; held, because of contribution rights,
estate's deduction limited to one-third of original amount of
debt, less amounts decedent had previously paid); McCue v.
Commissioner, a Memorandum Opinion of this Court dated Mar. 4,
1946 (decedent was one of 15 parties liable for a tax claim;
held, because taxpayer had not proved value of contribution
rights, estate's deduction limited to one-fifteenth of amount of
claim).
In this case, we cannot determine the value of decedent's
contribution rights on the basis of the number of obligors,
because much of decedent's share of the Land Bank loan has been
assumed by the children and their spouses.
As noted above, by the time of her death decedent had given
away all but 4.68 percent of the land constituting the family
farm. The deeds by which decedent made these gifts expressly
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