T.C. Memo. 1999-62 UNITED STATES TAX COURT VIOLET A. REYNOLDS, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 5708-97. Filed March 4, 1999. P and H cohabited for 24 years, H earning the income and P primarily taking care of the household. After H terminated the relationship, H sued P for ejectment, trespass, and conversion, praying in his complaint mainly for a judgment stating that P had no interest in property that was purchased during their relationship. P, in her answer, alleged that she had an equitable interest in the property. H, in settlement of the lawsuit, generally agreed to pay P $153,500 to perfect his sole ownership of all the property. R determined that the portion of the settlement that P received during the subject year was paid to her as compensation for the homemaking services that she provided during the relationship. Held: H paid P the disputed amount in satisfaction of her interest in the property, an interest that she had received as a gift from H during their relationship. Because P's basis in the property is greater than the settlement amount, none of the disputed amount is income to her.Page: 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
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