to consider tax consequences.  N.J.Stat.Ann. Sec. 2A:34-23.1j (West Supp.1993).


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The judgment of divorce granted Mollie a one-third interest in the VAY assets and stated that she was to receive one-third of the proceeds of the sale of those assets.  The language of the judgment made it clear that the value of Mollie's interest would thus fluctuate with the value of the VAY assets.  Accordingly, Mollie, not Vincent, would bear the burdens and harvest the benefits derived from her one-third interest in the VAY assets.  She alone would be saddled with any depreciation in the value of her interest.  The Tax Court acknowledged these characteristics of Mollie's interest, but discounted their significance in the determination of whether her interest was an ownership interest.   Indeed, if Vincent's work and skills were not available (either because he decided to leave the business or in the event of his death), the judgment provided that Mollie could force a sale of the assets.  Requiring Mollie to take control of the business might not be in the best interest of her one-third ownership interest in VAY, as well as Vincent's two-thirds ownership.  Accordingly, we conclude that the restrictions did not adversely affect Mollie's ownership.  Rather, they improved the prospects of profits from her ownership.  See Kenfield v. United States, 783 F.2d 966, 969 (10th Cir.1986) (control vested in former husband and former wife's deferred right to receive proceeds do not defeat the ownership interest of former wife in one-half of the