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After concessions,1 we must decide whether payments by James
Little to Fawni Hill from August 1, 1990, to December 31, 1991,
were alimony as respondent contends, or child support or other
nonalimony payments as petitioners contend. We hold that the
payments were alimony.
References to petitioner are to Fawni Hill, formerly Fawni
Little. Section references are to the Internal Revenue Code in
effect for the years in issue. Rule references are to the Tax
Court Rules of Practice and Procedure.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
A. Petitioners
Petitioners lived in Woodside, California, when they filed
their petition.
Petitioner worked full time as an office manager from 1968
to 1973. She obtained a bachelor’s degree at age 32. After
college, she started a business not otherwise described in the
record. She later worked 2 years for a space-planning firm. In
1 Respondent concedes that petitioners are not liable for
penalties under sec. 6662(a) for 1990 and 1991.
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