Gwinn

By this proceeding there is brought here for review a decision of the Board of Tax Appeals, wherein it was determined that one-half of the valu'e of certain real property, held by M. A. Gwinn and petitioner in joint tenancy at and prior to the death of M. A. Gwinn, was subject to an estate or succession tax under the provisions of the Revenue Act of 1924, approved June 2, 1924 ( 43 Stat. 303 , § 300 et seq.). The joint tenancy was created in June, 1915. Petitioner and M. A. Gwinn, his mother, contributed equal amounts to the purchase of the property. M. A. Gwinn died October 5, 1924. The Revenue Act provides (section 302, subd. (e), 26 USCA § 1094 note) that the estate tax shall be determined by including “ * * * the extent of the interest therein held as joint tenants by the decedent and any other person, * * * 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…