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In effect, having failed to achieve satisfaction in her
numerous appeals to the Michigan Supreme Court, petitioner seeks
to relitigate her domestic relations dispute here. We decline to
inject ourselves into this Michigan domestic relations dispute.
Marital relationships are peculiarly creatures of State law.
Lee v. Commissioner, 64 T.C. 552, 558 (1975), affd. per curiam
550 F.2d 1201 (9th Cir. 1977); see also Overman v. United States,
563 F.2d 1287, 1290 (8th Cir. 1977); Eccles v. Commissioner, 19
T.C. 1049, 1051 (1953), affd. per curiam 208 F.2d 796 (4th Cir.
1953).
Petitioner’s divorce judgment was entered in Midland County,
Michigan, on September 8, 1987. Although petitioner has
contested the validity of the divorce judgment, no State court
has overturned it. To the contrary, between 1988 and 1992, the
Michigan Supreme Court rejected petitioner’s several appeals
relating to her divorce.3 Principles of collateral estoppel and
full faith and credit counsel that we respect the State court
judgments. See Calhoun v. Commissioner, T.C. Memo. 1992-246
(declining to decide whether a New York divorce judgment was
invalid as violative of due process where no New York appellate
court had overturned, reversed, or otherwise modified the divorce
3 Notably, in Stark v. Midland Circuit Judge, 435 Mich. 877
(1990), the Michigan Supreme Court denied petitioner’s motion to
“disqualify a party.”
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