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inclusion in Marta's income in that year. For the reasons which
follow, we agree with the position espoused by both Norman and
respondent in their respective briefs.
In determining the substantive content of local judicial
action under these circumstances, this Court looks to applicable
local law. Taylor v. Commissioner, supra at 1138. In that
connection, Marta points to section 664 of the California Code of
Civil Procedure (West 1987), which provides that "In no case is a
judgment effectual for any purpose until entered." Marta also
relies on rule 232, California Court Rules (West 1996), which
states that a tentative decision is not a judgment, and "shall
not be binding on the court." Since the Judgment was not entered
until June 9, 1992, Marta maintains that nothing required Norman
to make the contested payments.
Although we do not dispute the law that Marta has brought to
our attention, we do not think it dispositive of the issue before
us. Section 577 of the California Code of Civil Procedure (West
1976) defines a judgment as the "final determination of the
rights of the parties in an action or proceeding." However, a
judgment is not the only type of decree sufficient for purposes
of section 71(b)(2)(C). A decree for support under section
71(b)(2)(C) includes "any type of court order or decree,
including an interlocutory decree of divorce or a decree of
alimony pendente lite", requiring one spouse to make payments for
the other spouse's support or maintenance. Sec. 1.71-1(b)(3),
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