Jean C. Carrieres v. Commissioner of Internal Revenue

Petitioner Carrieres appeals from the November 17, 1975, decision of the United States Tax Court which determined a $15,-844.01 deficiency in her federal income tax liability for 1968. The Tax Court based this decision on its opinion of August 27,1975, in which it held that “[t]o the extent, therefore, that one party receives [pursuant to a divorce decree] separate cash or other separate property, rather than community assets, in exchange for portions of his community property, he has sold or exchanged such portions and gain, if any, must be recognized thereon.” Carrieres v. Commissioner of…