Charles A. Attiliis v. Patricia L. Attiliis

CourtCourt of Appeals of Virginia
DecidedJune 9, 2009
Docket1087084
StatusUnpublished

This text of Charles A. Attiliis v. Patricia L. Attiliis (Charles A. Attiliis v. Patricia L. Attiliis) is published on Counsel Stack Legal Research, covering Court of Appeals of Virginia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Charles A. Attiliis v. Patricia L. Attiliis, (Va. Ct. App. 2009).

Opinion

COURT OF APPEALS OF VIRGINIA

Present: Judges Humphreys, Haley and Alston Argued at Alexandria, Virginia

CHARLES A. ATTILIIS MEMORANDUM OPINION * BY v. Record No. 1087-08-4 JUDGE ROBERT J. HUMPHREYS JUNE 9, 2009 PATRICIA L. ATTILIIS

FROM THE CIRCUIT COURT OF FAIRFAX COUNTY Paul F. Sheridan, Judge Pro Tempore

Edward V. O’Connor, Jr. (Edward V. O’Connor, Jr., P.C., on briefs), for appellant.

Ilona E. Grenadier (Arlene T. Starace; Jennifer Karrmann; Adrienne C. Wasserman; Grenadier, Anderson, Starace & Duffett, P.C., on brief), for appellee.

Charles A. Attiliis (“husband”) appeals the equitable distribution award made by the

circuit court pursuant to his divorce from Patricia L. Attiliis (“wife”). For the following reasons,

we affirm in part and reverse in part.

ANALYSIS

Husband makes four arguments on appeal regarding the circuit court’s equitable

distribution of the couple’s property: (1) the circuit court erred by valuing and distributing the

couple’s capital loss carry forward tax credit, (2) the circuit court erred by ordering husband to

maintain life insurance with wife as the beneficiary until he reaches 65 years of age, (3) the

circuit court erred by awarding money to wife for husband’s waste, dissipation of assets, and

negative non-monetary contributions, and (4) the circuit court erred in finding that husband’s

* Pursuant to Code § 17.1-413, this opinion is not designated for publication. adultery was the primary cause of the dissolution of the couple’s marriage. Wife raises an

additional issue, claiming that the circuit court erred by awarding her less than half of the value

of husband’s accounting business.

All of the issues presented on appeal relate to the circuit court’s equitable distribution of

the couple’s property. In fashioning an equitable distribution award, the court must consider the

factors in Code § 20-107.3(E). “[A]s long as the trial court considers all the factors, it is at the

court’s discretion to determine what weight to give each factor when making the equitable

distribution award.” O’Loughlin v. O’Loughlin, 20 Va. App. 522, 526, 458 S.E.2d 323, 325

(1995). We will not reverse a court’s equitable distribution unless it appears from the record that

the court “has abused [its] discretion, that [it] has not considered or has misapplied one of the

statutory mandates, or that the evidence fails to support the findings of fact underlying [its]

resolution of the conflict in the equities.” Robinette v. Robinette, 10 Va. App. 480, 486, 393

S.E.2d 629, 633 (1990). In light of those principles, we address each of the parties’ arguments.

A. The Capital Loss Tax Credit

Husband first argues that the circuit court erred by awarding wife money in exchange for

her interest in a tax credit held by the couple. Under federal tax law, an individual who suffers a

capital loss may use that loss to offset capital gains of a like nature and/or up to $3,000 of

ordinary income. See I.R.C. § 1211. Capital losses that cannot be fully used to offset income or

capital gains may be carried over to be used to offset income and/or capital gains the next year.

See id. Husband and wife sustained capital losses in 2005 and, at the time of the divorce, the

couple had not fully used the tax credit that they received for those losses.

In its final order, the circuit court made the following ruling on the capital loss carry

forward:

(2) Capital Loss Carry Forward: The Court finds that the total of this asset is a long term loss carry forward of $75,000.00 and a -2- short term loss carry forward [of] $40,070.00, but [husband’s] lack of disclosure with regard to the value of the use of this asset, he being a CPA and obviously with the knowledge of the value and use of this asset hindered the Court with regard to this asset. From the evidence deduced, the Court orders [husband] to pay to [wife] the sum of $50,000.00 as her interest in the item.

Husband argues that the circuit court’s award of $50,000 was erroneous because the evidence

was insufficient to prove the amount of the tax credit that the couple possessed.

At the hearing before the circuit court, wife introduced, without objection, an exhibit

listing assets owned by the couple and the value of those assets. One of the assets listed was

“Capital Loss shown on tax returns (loss of $75,000).” Wife’s attorney presented the list to

husband and asked him to compare the list of assets to his records. After reviewing the list, the

following exchange took place:

[Husband]: Capital loss on tax return, you’re calling that an asset?

[Attorney]: Yes, sir.

[Husband]: I’m not aware that that’s an asset.

[Attorney]: I understand, but there was a capital loss at that time.

[Husband]: It wasn’t $75,000.

At that point, the attorney stopped asking about the capital loss and began questioning husband

about another asset.

Wife subsequently offered a draft of the couple’s 2005 tax return into evidence. The tax

return did not indicate that the couple had a $75,000 capital loss tax credit. Instead, the return

indicated that the couple had a “Net short-term capital gain or (loss)” of “-40,070.” The section

of the 2005 tax return titled “Long-Term Capital Gains and Losses” was blank.

During wife’s closing arguments, the attorneys clarified the amount of the capital loss tax

credit:

-3- [Wife’s Attorney]: The next item is capital loss carry forward is an asset. I was under the impression it was $75,000. [Husband’s attorney] corrected me. We went through the tax return yesterday, which it was $40,000 and now it’s $37,070.

[Husband’s Attorney]: The total was $40,000. They claimed a $3,000 deduction in 2005.

[Wife’s Attorney]: And we are claiming half of that. They filed joint returns, and so they would be filing separate returns from here forward which brings me to the fact that I can’t tell you if [husband] used it or not, because it’s not been updated.

I don’t have his ’06 tax return. He didn’t provide it. We did provide Mrs. Attiliis.’ So, I don’t know if he used it in ’06 or not, but we would request that he provide for it if he did.

In light of wife’s concession regarding the amount of capital loss carry forward, and the

couple’s 2005 tax return, it is apparent that the remaining amount of the tax credit was, at most,

$37,070, not $75,000. The court found that the couple had a $75,000 long-term capital loss carry

forward and a $40,070 short-term capital loss carry forward. The evidence does not support that

finding. 1 Because that factual finding was essential to the court’s distribution of that asset, we

reverse and remand that issue for consideration in light of the proper facts.

B. Life Insurance

In its final order, the circuit court ordered husband to continue to carry four term life

insurance policies, until he reaches the age of 65, with wife as the sole beneficiary. Husband

1 At oral argument, wife conceded that the evidence does not support a $75,000 long-term capital loss carry forward. -4- argues that the circuit court had no authority to order him to maintain life insurance as part of

the equitable distribution. We agree.

Jurisdiction in divorce suits is purely statutory. Lapidus v. Lapidus, 226 Va. 575, 578,

311 S.E.2d 786, 788 (1984). “When the General Assembly sets out to confer . . .

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