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indicated, all section references are to the Internal Revenue
Code in effect for the year in issue.
FINDINGS OF FACT
Some of the facts have been stipulated, and the stipulated
facts are incorporated in our findings by this reference.
Petitioner resided in California at the time that she filed her
petition. Petitioner was previously married to Jon Sarchett (her
former spouse). The marriage of petitioner and her former spouse
was dissolved through proceedings commenced in the Los Angeles
County Superior Court in 2001 and concluded in 2004. Attached to
and made part of the judgment of dissolution of the marriage was
the agreement between petitioner and her former spouse, each
represented by attorneys, as to spousal support and property
division. Section I of the agreement provided for the division
of community property. After listing specifically property
awarded to petitioner or to her former spouse, the agreement
provided:
II. EQUALIZATION PAYMENT
A. In order to equalize the division of the
parties community property and debts, * * * [Toni
Sarchett] shall pay to * * * [Jon Sarchett] the sum of
two hundred twenty-five thousand * * * dollars. Said
sum shall be paid to * * * [Jon Sarchett] as set forth
in the following schedule:
1. * * * [Toni Sarchett] shall pay to * * *
[Jon Sarchett] the sum of one hundred twenty-five
thousand * * * dollars on or before May 10, 2004;
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