Ronald R. Armacost and Cathy L. Armacost - Page 2
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US Tax Court > 1998 > Ronald R. Armacost and Cathy L. Armacost - Page 2
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The sole issue for decision is whether interest payments on a
promissory note made by Ronald Armacost (petitioner) to his ex-
wife are deductible.
Some of the facts have been stipulated and are so found.
The stipulation of facts and the attached exhibits are
incorporated herein by reference. Petitioners resided in Liberty
Lake, Washington, at the time their petition was filed.
FINDINGS OF FACT
Petitioner married Linda L. Armacost in 1963. During their
marriage, petitioner and Linda Armacost accumulated numerous
assets, including stocks, bonds, a personal residence, vacation
properties, and other liquid assets. They also acquired several
commercial properties on which they developed, constructed, and
operated gas stations and convenience stores.
Petitioner and Linda Armacost resided only in the community
property States of Washington or Idaho during their marriage;
therefore most of their assets were owned in undivided one-half
In January 1985, petitioner and Linda Armacost legally
separated. They agreed to divide their property equally and
executed a Separation Agreement designating which property would
be allocated to whom. All their property, along with its "value
at date of dissolution", was divided as follows:
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