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              
          interests.                                                                   
               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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