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contract law that writings should be interpreted as a whole and
the interpretation should give a reasonable meaning to all parts
of the writing. Accordingly, we find that the divorce documents
provide that the annual payments were to terminate on the death
of Ms. Springer; thus, the $50,000 payment made by petitioner to
Ms. Springer in 1996 is deductible as alimony under section
215(a).
II. Nebraska Law
Even if the terms of the divorce documents did not provide
for termination on the death of Ms. Springer, petitioner would
still prevail as long as the annual payments would have
terminated under Nebraska law.14 On brief, the parties addressed
whether Nebraska statutory law provides for the termination of
the annual payments under the facts of this case. The relevant
statute, Neb. Rev. Stat. section 42-365 (1998), provides:
When dissolution of a marriage is decreed, the
court may order payment of such alimony by one party to
the other and division of property as may be
reasonable, having regard for the circumstances of the
parties, duration of the marriage, a history of the
contributions to the marriage by each party, including
contributions to the care and education of the
children, and interruption of personal careers or
educational opportunities, and the ability of the
supported party to engage in gainful employment without
interfering with the interests of any minor children in
the custody of such party. Reasonable security for
payment may be required by the court. Unless amounts
14For purposes of this discussion, we assume that the
divorce documents did not provide for termination of the annual
payments on the death of Ms. Springer.
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