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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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