Lee E. Seidel - Page 17

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          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.                               





















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