Dewey and Carlena K. Hammond - Page 3

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          divorce decree are deductible alimony payments or, in the                   
          alternative, nondeductible child support payments.                          
               Petitioners resided in Rome, Georgia, at the time they filed           
          their amended petition.                                                     
                                     Background                                       
               The background facts related below are derived from the                
          pleadings in this case, affidavits filed by both respondent's               
          counsel and petitioner, the exhibits attached thereto, and the              
          uncontroverted written representations of the parties.                      
               Dewey and Rebecca had one child, Justin Joel Hammond                   
          (Justin), who was born in July 1985.  In September 1988, Rebecca            
          brought an action for divorce in the Superior Court of Gordon               
          County, Georgia (Superior Court); a jury verdict was subsequently           
          rendered.  A "Final Judgment and Decree" of divorce (Judgment)              
          incorporating the jury verdict was entered by the Superior Court            
          on October 31, 1988.                                                        
               Paragraph 1 of the Judgment awarded Rebecca semimonthly                
          child support payments for Justin of $575, or $1,150 per month,             
          until Justin attained 18 years of age, died, married, or joined             
          the military.                                                               
               Paragraph 2 of the Judgment provides as follows:                       
                                       ALIMONY                                        
                    Upon said jury verdict, IT IS ORDERED, DECREED and                
               ADJUDGED that the defendant DEWEY HAMMOND, III, pay to                 
               REBECCA HAMMOND the sum of $2,000.00 per month as                      
               alimony commencing October 1, 1988, and ending on                      
               JUSTIN JOEL HAMMOND'S eighteenth birthday, or at the                   




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