DeAnna S. Dotson and Robert L. Dotson - Page 3

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               Respondent determined a $1,950 deficiency in petitioners’              
          2000 Federal income tax.  The issue for decision is whether                 
          petitioners must include in gross income payments that Deanna S.            
          Dotson (hereinafter petitioner) received with respect to her ex-            
          husband’s military pension.                                                 
               The parties submitted this case fully stipulated pursuant to           
          Rule 122.  The stipulated facts are so found.                               
               On July 5, 1963, petitioner married Chris L. Jefferies (Mr.            
          Jefferies).  For some unspecified number of years during the                
          marriage, Mr. Jefferies served in the U.S. Air Force.                       
               In 1980 petitioner filed for a divorce.  She and Mr.                   
          Jefferies entered into a separation agreement (the separation               
          agreement) to settle their affairs.  Paragraph 3 of the                     
          separation agreement states in pertinent part:                              
                    The parties make the following disposition and                    
               settlement in regard to the real and personal property                 
               accumulated by them during the course of their                         
                         *    *    *    *    *    *    *                              
                         b) Petitioner shall have and retain one-half                 
               of the stocks and bonds currently owned by the parties,                
               the Plymouth van and one-half of Respondent’s [Mr.                     
               Jefferies’] military retirement income upon his                        
               retirement from the military based on 20 years service                 
               and at the grade of Lt. Colonel.                                       
                         *    *    *    *    *    *    *                              

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