Andrea Cipriano - Page 2




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               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).               





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