Matter of Marriage of Engle

*209PETERSON, J.

A husband and wife, after over 25 years of marriage, are divorcing. The value of their property is nearly two million dollars. The issues solely relate to the division of the property, and tax consequences thereof. The case involves consideration of the holding of United States v. Davis, 370 US 65, 82 S Ct 1190, 8 L Ed 2d 335 (1962), and amendments to ORS 107.105(1)(e), amendments which were enacted in response to the decision of the Court of Appeals in this case, and which are now applicable to this case. We granted review to consider whether a court-ordered transfer to the wife…