Dennis E. and Paula W. Lofstrom - Page 4

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          including petitioners’ answers to interrogatories, over                     
          respondent’s objections, but warned petitioners that we would               
          accord little weight to the documents.  To hold otherwise would             
          prejudice respondent because he did not have the opportunity to             
          cross-examine petitioners regarding the authenticity of the                 
          documents or the veracity of petitioners’ answers to                        
          interrogatories.  We stand by that ruling.  The factual                     
          background is therefore based on the stipulation of facts and               
          exhibits submitted to the Court.                                            
               Petitioner Dr. Dennis Lofstrom (Mr. Lofstrom) leads a very             
          active life.  For most of his life, Mr. Lofstrom lived and worked           
          in Minnesota, where he raised a family of 11 children with his              
          wife, Dorothy Lofstrom (Dorothy).  Mr. Lofstrom later divorced              
          Dorothy and retired from his full-time medical practice.  Mr.               
          Lofstrom embarked at age 70 in 1995 upon a medical missionary               
          trip to Antarctica with his second wife, Paula Lofstrom (Paula).            
          Petitioners embarked upon another medical missionary trip in 2002           
          to serve at a hospital in Tanzania, Africa, for 5 years.                    
               This case concerns three varieties of deductions that                  
          petitioners claimed in 1997 and 1998.  The first relates to                 
          alimony.                                                                    
          Alimony Deduction                                                           
               Mr. Lofstrom was ordered to pay Dorothy $1,500 per month in            
          alimony (or support maintenance payments) pursuant to their                 






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