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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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Last modified: May 25, 2011