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Revenue Code in effect for the years at issue. Rule references
are to the Tax Court Rules of Practice and Procedure.
FINDINGS OF FACT
A. Background
Mrs. Spector (formerly Mrs. Ehrenworth) and Dr. Ehrenworth
were married in June 1955. They had four children (Richard,
Andrew, Robert, and Douglas). They filed cross-motions for
divorce around 1977. Mrs. Spector and Dr. Ehrenworth settled the
property distribution and alimony issues at a conference before
the Superior Court of New Jersey, Chancery Division, Essex County
on March 13, 1980.
Dr. Ehrenworth earned a large amount of income while he was
married to Mrs. Spector. She earned little or no income during
those years.
The Ehrenworths lived in New Jersey, and the Spectors lived
in California, when they filed their petitions.
B. The Property Settlement
On July 3, 1980, Mrs. Spector and Dr. Ehrenworth signed a
"Property Settlement and Support Agreement" (the support
agreement). In it, among other things, Mrs. Spector waived all
rights she had to any interest in Dr. Ehrenworth's pension fund
and medical practice. She also conveyed by deed any interest she
had in a medical building and any rights she had to shares in the
Phoenix Corp. The Phoenix Corp. is an inactive company that has
never had any assets. Dr. Ehrenworth agreed to pay Mrs. Spector
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