United States v. Davis

Thomas Davis (plaintiff) transferred appreciated stock to his ex-wife under their divorce agreement in exchange for her giving up her statutory marital rights in his property, rights recognized under Delaware's common-law property regime. The government (defendant) treated the transfer as a taxable event; Davis sought a redetermination, and the court of claims agreed the transfer might be taxable in theory but found it impossible to value the wife's inchoate rights, ruling for Davis. The Supreme Court granted certiorari.