George C. Eblen and June M. Eblen v. Commissioner of Internal Revenue

George Eblen appeals from United States Tax Court decisions assessing income tax deficiencies arising from disagreements concerning Eblen’s treatment of the gain on the sale of a farm pursuant to a property settlement agreement. The historical facts of this case are not disputed.

Eblen was married to Bettye H. Eblen in 1943. In 1961 Eblen inherited Eastover Farm from his father, which was held in trust for him until 1971. Eastover was the Eblens’ residence until 1972, when Bettye filed a petition for divorce. The Eblens executed a property settlement agreement which provided that Eastover…