Frances J. Ryan - Page 2

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          cases were consolidated on August 20, 1997, for purposes of                 
          trial, briefing, and opinion.                                               
               Respondent determined deficiencies in Frances J. Ryan's                
          Federal income taxes for 1991, 1992, and 1993 in the amounts of             
          $1,950, $1,950, and $1,950, respectively.  Respondent determined            
          a deficiency in Gregory Ryan's Federal income tax for 1991 in the           
          amount of $4,030.  Respondent determined deficiencies in Gregory            
          and Patricia Ryan's Federal income taxes for 1992 and 1993 in the           
          amounts of $3,954 and $4,019, respectively.                                 
               The issue for decision is whether the $13,000 paid by                  
          Gregory Ryan to his former wife, Frances Ryan, during each of the           
          taxable years in issue is alimony.                                          
               Some of the facts have been stipulated and are so found.               
          The stipulation of facts and the attached exhibits are                      
          incorporated herein by reference.  Frances Ryan resided in                  
          Charlotte, North Carolina, at the time her petition was filed.              
          Gregory Ryan and his wife, Patricia Ryan, resided in Schofield,             
          Wisconsin, at the time their petition was filed.                            
                                  FINDINGS OF FACT                                    
               On December 29, 1989, after a trial, Gregory and Frances               
          Ryan were granted a divorce by the Circuit Court for the County             
          of Kalamazoo, Michigan (trial court).  The Judgment of Divorce              

          references are to the Tax Court Rules of Practice and Procedure.            

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