Siewert v. Commissioner
United States Tax Court
Held: A property settlement agreement entered on May 2, 1972, between petitioner and his former wife, incorporated in their divorce decree of the same date, did not call for an approximately equal division of their community property but for a sale or exchange.
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Held: A property settlement agreement entered on May 2, 1972, between petitioner and his former wife, incorporated in their divorce decree of the same date, did not call for an approximately equal division of their community property but for a sale or exchange. Petitioner's basis in the community assets allocated to him under the agreement must be adjusted to reflect such unequal division as well as the payments he obligated himself to make from noncommunity property sources. Held, further, that the sale or exchange between petitioner and his former wife with respect to their community…
1Opinion of the Court
Courtney L. Siewert, Petitioner v. Commissioner of Internal Revenue, Respondent
Siewert v. Commissioner
Docket No. 169-77
United States Tax Court
72 T.C. 326; 1979 U.S. Tax Ct. LEXIS 120;
May 14, 1979, Filed
Decision will be entered under Rule 155.
Held: A property settlement agreement entered on May 2, 1972, between petitioner and his former wife, incorporated in their divorce decree of the same date, did not call for an approximately equal division of their community property but for a sale or exchange. Petitioner's basis in the community assets allocated to him under the agreement must be…
2Cases cited28 opinions
- Cockerham v. CockerhamTexas Supreme Court · 1975
- McWilliams v. CommissionerSupreme Court of the United States · 1947
- Fred M. Waring and Virginia Waring v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1969
- Columbus & G. R. Co. v. CommissionerUnited States Tax Court · 1964
- Deyoe v. CommissionerUnited States Tax Court · 1976
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