6
action is between them, and does not affect the rights of the
fisc.
We accordingly conclude that the distribution to petitioner
from Mr. Willadsen's pension and thrift funds in 1990 was to
petitioner as alternate payee and was taxable to her under the
provisions of section 402(a)(9).
Decision will be entered
under Rule 155.
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Last modified: May 25, 2011