- 2 - Federal income tax liabilities for 1996, 2000, 2001, 2002, and 2003, representing a cumulative total of $44,383.1 Unless otherwise indicated, all section references are to the sections of the Internal Revenue Code applicable to this collection action, and all Rule references are to the Tax Court Rules of Practice and Procedure. Background The facts of this case have been submitted fully stipulated under Rule 122 and are so found. Petitioner is a resident of Oregon. Petitioner has been employed as a nurse for many years. In 2001, petitioner was divorced from her husband of 8 years. As part of the divorce from her husband and separation of their marital property, in 2001 petitioner was to receive assets with a value of $26,480, including an interest in real property located at 400 Lake Street, Berrien Springs, Michigan (the Michigan property). The interest had a value of $25,000 to petitioner, as specified by the divorce court. The June 6, 2001, judgment in dissolution of petitioner’s marriage expressly awarded to petitioner “all the parties’ 1 Petitioner’s OIC also related to additional outstanding Federal income tax liabilities petitioner owed for 1995 but which are not otherwise involved in this case.Page: Previous 1 2 3 4 5 6 7 8 NextLast modified: March 27, 2008