- 13 - record before us. See, e.g., Stiles v. Commissioner, T.C. Memo. 1981-711. With regard to the fourth factor, it does not appear that the payments were secured by any of Mr. Rangos' assets. The absence of this factor favors treating the payments as alimony. With regard to the fifth factor, petitioner received the following pursuant to the Agreement: (1) A $90,000 equity interest in the marital residence; (2) certain items of household furnishings; (3) maintenance payments for the children; (4) alimony payments of $2,083.33 per month; (5) use of a new Cadillac Eldorado or the equivalent every 3 years; (6) beneficiary rights in Mr. Rangos' $200,000 life insurance policy in trust; and (7) a right to use a Florida condominium owned by Mr. Rangos. We believe the value of all the assets (including the use of a new Cadillac every 3 years) received by petitioner was less than one-half of the value of the property accumulated by petitioner and Mr. Rangos during their marriage. This factor favors treating the payments as part of a property settlement. With regard to the sixth factor, we believe petitioner's needs were taken into consideration in determining the amount of the car payments. Thus, this factor favors treating the payments as alimony. Finally, with regard to the seventh factor, a separate provision for support (Paragraph 11) was clearly enunciated in thePage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
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