Lee E. Seidel - Page 17
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negotiations during the dissolution of petitioner’s and Ms.
As stated in Powell v. Commissioner, supra at 498-499:
Our conclusion is not affected by the fact that initially
the entire distribution was made to * * * [Ms. Seidel]. We
think * * * [she] received the distribution * * * on behalf
of the community and that * * * [her] later payment to * * *
[petitioner], * * * [by way of cash and relief of joint
liabilities], was a transfer to * * * [him] of funds that at
all times belonged to * * * [him].
Respondent’s computational adjustment to petitioner’s
claimed miscellaneous itemized deductions will be decided by our
holding on the issue.
Reviewed and adopted as the report of the Small Tax Case
Decision will be entered
under Rule 155.
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Last modified: May 25, 2011