Ellen M. Rangos - Page 13

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          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 the          





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