husband's independent liability.  In the words of the Court, "the inchoate rights granted a wife in her husband's property by the Delaware law do not even remotely reach the dignity of co-ownership."  Id. at 70, 82 S.Ct. at 1193.   The Court emphasized that the wife's rights "might be ascertained independently of the extent of the husband's property by such criteria as the wife's financial condition, her needs in relation to her accustomed station in life, her age and health, the number of children and their ages, and the earning capacity of the husband."  Id.  The Court further held that the wife's basis in the transferred property would be its fair market value on the date of transfer to her.  Id. atunder New Jersey law, Mollie's interest in the Yonadis' marital property immediately prior to the transfer directed by the divorce decree was like that of a co-owner.  If so, the transfer to her of an interest in the VAY assets at the time of her divorce was a non-taxable division of property, she thereafter held the interest assigned to her with a carryover basis, and upon the sale of the VAY assets, she became liable for the capital gains tax on the difference between the cash she received and the carried-over share of Vincent's basis in those assets attributable to her interest.  Thus, if the court is right that "Mollie's interest resulted from a division of property that can be characterized as already co-owned by her