- 2 - After settlement of some issues, the primary issue for decision is whether certain amounts petitioner received in connection with a division of marital property constitute taxable interest income. Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the years in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure. FINDINGS OF FACT Some of the facts have been stipulated and are so found. At the time the petition was filed, petitioner resided in Basking Ridge, New Jersey. Petitioner is well educated. In 1964, petitioner received a bachelor of arts degree in teaching from William Paterson College. In 1984, petitioner received a masters degree in business administration from Fairleigh Dickenson University. Since 1987, petitioner has been employed as a revenue agent for respondent. Petitioner also is a certified public accountant and teaches accounting and tax courses part time at Ramapo College. Petitioner’s ex-spouse is an attorney and maintains a law practice in New Jersey. On March 17, 1993, petitioner and her ex-spouse divorced and entered into a property settlement agreement (the agreement).Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
Last modified: May 25, 2011