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in 1982, when petitioner’s disposable income dropped
precipitously.
The remodeling of the family residence was completed and
paid for prior to Mr. Heitzman’s ever having contemplated the
purchase of his interest in Stonehurst and was not funded in any
way by the tax savings. Indeed, petitioner had used her own
limited resources in 1979 to make additional improvements to the
residence. Even if the cost of remodeling could have been traced
indirectly to the tax savings, the remodeling contributed little
to any increase in the value of the residence between 1979 and
1982, when it was sold pursuant to their divorce settlement.
Such increases were entirely attributable to market forces and
the desirable location and quality of the house.
Another factor to be taken into account is the 1983 divorce
between petitioner and Mr. Heitzman. Flynn v. Commissioner, 93
T.C. at 367; sec. 1.6013-5(b), Income Tax Regs. There is nothing
in the record to indicate that petitioner received any more in
the divorce settlement, which primarily consisted of her share of
the proceeds from the sale of the residence and about $14,000 in
alimony, than she otherwise would have. In view of the standard
of living that petitioner and Mr. Heitzman enjoyed while married,
such a settlement is well within the bounds of normal support.
See, e.g., Foley v. Commissioner, T.C. Memo. 1995-16. The
divorce also takes on added importance in light of the provision
in the settlement agreement whereby Mr. Heitzman agreed to
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