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CourtListener opinion 4331479

Date unknown · US

Extracted case name
pending
Extracted reporter citation
pending
Docket / number
27001-95
QDRO relevance 5/5Retirement relevance 2/5Family-law relevance 5/5gold label pending
Research-use warning: This page contains machine-draft public annotations generated from public opinion text. The headnote is not Willie-approved gold-label work product and is not legal advice. Verify the full opinion and current law before relying on it.

Machine-draft headnote

Machine-draft public headnote: CourtListener opinion 4331479 is included in the LexyCorpus QDRO sample set as a public CourtListener opinion with relevance to QDRO procedure / domestic relations order issues. The current annotation is conservative: it identifies source provenance, relevance signals, and evidence quotes for attorney/agent retrieval. It is not a Willie-approved legal headnote yet.

Retrieval annotation

Draft retrieval summary: this opinion has QDRO relevance score 5/5, retirement-division score 2/5, and family-law score 5/5. Use the quoted text and full opinion below before relying on the case.

Category: QDRO procedure / domestic relations order issues

Evidence quotes

QDRO

Court of the State of California, County of Los Angeles (Superior Court), issued an interlocutory judgment that dissolved the marriage and awarded Mrs. Glassman a portion of Mr. Oddino's retirement benefits. On March 24, 1989, the Superior Court issued a Qualified Domestic Relations Order (QDRO) that modified and clarified the interlocutory judgment. The QDRO directed the Hughes Plan to: (1) Pay Mrs. Glassman 36.6231 percent of Mr. Oddino's \accrued benefit[s] as of April 1

domestic relations order

the State of California, County of Los Angeles (Superior Court), issued an interlocutory judgment that dissolved the marriage and awarded Mrs. Glassman a portion of Mr. Oddino's retirement benefits. On March 24, 1989, the Superior Court issued a Qualified Domestic Relations Order (QDRO) that modified and clarified the interlocutory judgment. The QDRO directed the Hughes Plan to: (1) Pay Mrs. Glassman 36.6231 percent of Mr. Oddino's \accrued benefit[s] as of April 1

Source and provenance

Source type
courtlistener_qdro_opinion_full_text
Permissions posture
public
Generated status
machine draft public v0
Review status
gold label pending
Jurisdiction metadata
US
Deterministic extraction
docket: 27001-95
Generated at
May 14, 2026

Related public corpus pages

Deterministic links based on shared title/citation terms and QDRO / retirement / family-law retrieval scores.

Clean opinion text

T.C. Memo. 1997-497

 UNITED STATES TAX COURT

 JEFFREY A. GLASSMAN and MARY K. GLASSMAN, Petitioners v.
 COMMISSIONER OF INTERNAL REVENUE, Respondent

 Docket No. 27001-95. Filed November 5, 1997.

 Terrence J. Moore, for petitioner.

 Mary Tseng Klaasen, for respondent.

 MEMORANDUM FINDINGS OF FACT AND OPINION

 FOLEY, Judge: Respondent determined a deficiency of

$17,047.96 in petitioners' 1992 Federal income tax. Unless

otherwise indicated, all section references are to the Internal

Revenue Code in effect for the year in issue, and all Rule

references are to the Tax Court Rules of Practice and Procedure.
 - 2 -

After concessions, the issues for decision are whether

petitioners' expenditures for legal services, which respondent

agrees are deductible pursuant to section 212, are subject to

section 67(a), and alternatively whether such expenditures are

capital expenditures. We hold that petitioners' section 212

deduction is subject to section 67(a) and that their expenditures

are not capital expenditures.

 FINDINGS OF FACT

 The parties submitted this case fully stipulated pursuant to

Rule 122. At the time Jeffrey and Mary Glassman filed their

petition, they resided in Lake Forest, California.

 In 1954, Mary Glassman married James M. Oddino. During

their marriage, Mr. Oddino was employed by the Hughes Aircraft

Company and participated in the Hughes Non-Bargaining Retirement

Plan (Hughes Plan). On January 19, 1983, the Superior Court of

the State of California, County of Los Angeles (Superior Court),

issued an interlocutory judgment that dissolved the marriage and

awarded Mrs. Glassman a portion of Mr. Oddino's retirement

benefits. On March 24, 1989, the Superior Court issued a

Qualified Domestic Relations Order (QDRO) that modified and

clarified the interlocutory judgment. The QDRO directed the

Hughes Plan to: (1) Pay Mrs. Glassman 36.6231 percent of Mr.

Oddino's \accrued benefit[s] as of April 1