Barbara owns an incorporated consulting business and has spent many years building its respectable reputation.

However business recently has dropped dramatically because of the unprofessional behavior of cliff, Barbara's husband. Barbara feels that the only way to protect her business is to divorce cliff. Cliff demands 50 percent of the stock in Barbara's business. The divorce will be costly because cliff and Barbara cannot reach an agreement about the business's stock. Are the costs of the divorce deductible to Barbara or to cliff?

Prepare a file memorandum for tax research. Thus, go further in your research than just finding a Code section. Arrive at a tenable conclusion. (Text book Sawyers federal tax research 10th edition chapter 6 question 71)