- 16 - negotiations during the dissolution of petitioner’s and Ms. Seidel’s marriage. As stated in Powell v. Commissioner, supra at 498-499: Our conclusion is not affected by the fact that initially the entire distribution was made to * * * [Ms. Seidel]. We think * * * [she] received the distribution * * * on behalf of the community and that * * * [her] later payment to * * * [petitioner], * * * [by way of cash and relief of joint liabilities], was a transfer to * * * [him] of funds that at all times belonged to * * * [him]. Respondent’s computational adjustment to petitioner’s claimed miscellaneous itemized deductions will be decided by our holding on the issue. Reviewed and adopted as the report of the Small Tax Case Division. Decision will be entered under Rule 155.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17
Last modified: May 25, 2011