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conclusion that the parties did not intend for petitioner to
include the automobile payments as income.
Ambiguous language in a contract is to be resolved against the
drafter of the agreement. Rink v. Commissioner, 100 T.C. 319, 328
n.8 (1993), affd. 47 F.3d 168 (6th Cir. 1995); see, e.g., United
States v. Seckinger, 397 U.S. 203, 216 (1970). Accordingly, we
construe any ambiguity of Paragraph 12 against Mr. Rangos.
Considering all the facts and circumstances, we hold that the
amounts paid by Mr. Rangos for the purpose of furnishing petitioner
with an automobile in 1991 and 1994 are in the nature of a property
settlement, and therefore not includable in her income for those
years.
To reflect the foregoing and respondent's concessions,
Decisions will be entered
for petitioner.
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