Randolph John Beale - Page 7




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            he paid to Ms. Eads and Ms. Tang were deductible as alimony                                
            during the years in issue under section 215.                                               
                  Ms. Eads                                                                             
                  Section 2153 provides a deduction for amounts paid by a                              
            taxpayer to a former spouse if the payee spouse is required to                             
            include these amounts in gross income under section 71.4                                   















                  3Sec. 215 was amended by the Deficit Reduction Act of 1984                           
            (DEFRA), Pub. L. 98-369, sec. 422(b), 98 Stat. 494, 797.  The                              
            amendment applies to divorce or separation instruments (as                                 
            defined in sec. 71(b)(2), as amended) executed after Dec. 31,                              
            1984, or executed before Jan. 1, 1985, but modified on or after                            
            that date if the modification expressly provides that the                                  
            amendments to sec. 215 apply to the modification.  This                                    
            amendment is not applicable to petitioner's divorce from Ms.                               
            Eads, and references to sec. 215 are to this section before its                            
            amendment.                                                                                 
                  4Sec. 71 was amended by DEFRA sec. 422(a), 98 Stat. 795.                             
            The amendment applies to divorce or separation instruments (as                             
            defined in sec. 71(b)(2), as amended) executed after Dec. 31,                              
            1984, or executed before Jan. 1, 1985, but modified on or after                            
            that date if the modification expressly provides that the                                  
            amendments to sec. 71 apply to the modification.  This amendment                           
            is not applicable to petitioner's divorce from Ms. Eads, and                               
            references to sec. 71 are to this section before its amendment.                            





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