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Finally, petitioners assert that it would be "inequitable"
to treat the payments in dispute as child support. Regrettably
for petitioners, this Court is not a court of equity and does not
possess general equitable powers. Stovall v. Commissioner, 101
T.C. 140, 149-150 (1993) (citing Commissioner v. McCoy, 484 U.S.
3 (1987)). Even a District Court, with equitable powers, cannot
disregard statutory terms. See INS v. Pangilinan, 486 U.S. 875,
883 (1988). Therefore, petitioners' argument on this score is
unavailing.
We have considered the remaining arguments of petitioners
and, to the extent we have not addressed them, find them to be
unconvincing. We hold that petitioners are not entitled to
alimony deductions in the amount of $24,000 claimed on each of
their returns for taxable years 1993, 1994, and 1995.
To reflect the foregoing and concessions,
An appropriate order
granting respondent's motion
for partial summary judgment and
denying petitioners' cross-motion
for partial summary judgment will
be issued, and decision will be
entered under Rule 155.
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