This 2002 article explores the tax consequences of transfers in divorce and suggests how the tax consequences can be both simplified and rationalized. This article was written as an "Academic Adviser" to the Joint Committee on Taxation in connection with a study mandated by Congress on the overall state of the Federal tax system (June 2000 through April 2001) and was first published at JOINT COMMITTEE ON TAXATION, STUDY OF THE OVERALL STATE OF THE FEDERAL TAX SYSTEM AND RECOMMENDATIONS FOR SIMPLIFICATION JCS-3-01, VOLUME III (ACADEMIC PAPERS), April, 2001, at 19.