Welwood v. Comm’r, T.C. Memo. 2019113, 2019 WL 4187568 (2019)
(a) Facts: Husband and wife were married in 1973. They separated in Florida 2003 and signed an agreement dividing their property.
In the agreement, the husband conveyed to the wife a 50% interest in certain real estate partnerships. The partnerships were designed to generate tax savings in early years. A 1986 tax law change limiting the deduction of passive losses against other income made the partnerships much less attractive in their later years. Continue reading →