FINDINGS OF FACT
In April 1990 Ann married Vince Carrino in California. He was, and remains, an exceptionally skilled financial manager who has operated a number of volatile hedge funds. Managing those funds between 1989 and 2003 was, according to Vince, “kind of like riding a roller coaster blindfolded and naked through a nuclear power plant; [it was] not a pleasant experience.” The stress built up, and the marriage deteriorated. In June 2002, Vince petitioned to dissolve the marriage. While he and Ann legally separated four days later, the divorce action dragged on for more than four years.
I. CR Traders
Vince started a new hedge fund the same year he separated from Ann. In January 2002, he had formed a limited liability company called CR Traders, LLC (CR LLC), and named himself the managing member. That entity served as general partner to a partnership that Vince (in his capacity as manager of CR LLC) created on June 6, 2002--CR Traders Partners, L.P. (CR LP). Although Vince made capital contributions to CR LLC (about $850,000) sometime in 2002--which CR LLC then contributed to CR LP--neither of those contributions occurred before he and Ann legally separated in June 2002. CR LP began operating as a hedge fund in September 2002, and Vince managed it through CR LLC. Even though they were still married (but legally separated) at the time, Vince apparently made this investment without notifying Ann--much less obtaining her consent.
Judge(s): Mark Holmes
Jurisdiction: U.S. Tax Court
Related Categories: Domestic Relations , Taxation
|Circuit Court Judge(s)|
|Petitioner Lawyer(s)||Petitioner Law Firm(s)|
|Respondent Lawyer(s)||Respondent Law Firm(s)|
|Rebecca Duewer-Grenville||Internal Revenue Service|
|Jon Feldhammer||Internal Revenue Service|