Thomas H. Nelson and Donna J. Zullo Nelson - Page 8

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          between the parties can be resolved merely by examining the                 
          divorce decree in order to determine whether certain payments               
          petitioner was obligated to make fit within the definition of               
          alimony set forth in section 71(b).  After doing so, we conclude            
          that petitioners are entitled to the alimony deductions here in             
          dispute because all of the requirements set forth in the relevant           
          statutes have been satisfied.  The possibility that the payments            
          might have represented a division of marital property, as                   
          suggested by the local courts after the effective date of the               
          divorce decree, makes no difference.                                        
               To reflect the foregoing,                                              
                                             Decision will be entered                 
                                        for petitioners.                              

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