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In summary, petitioner has failed to demonstrate that he
undertook the minority education business with the actual and
honest objective of making a profit. Accordingly, we find on the
basis of the facts and circumstances of this case that peti-
tioner's activity with respect to the minority education business
is not an activity engaged in for profit and is therefore subject
to the limitations imposed by section 183.
The second issue for decision is whether payments of $2,400
to petitioner's former wife constitute deductible alimony. Peti-
tioner deducted $2,400 for monthly payments made to his former
wife pursuant to their separation agreement. Respondent dis-
allowed this deduction in the notice of deficiency.
Section 215(a) permits a deduction for the payment of
alimony during a taxable year. Section 215(b) defines alimony by
reference to section 71(b). Section 71(b)(1) defines alimony as
any cash payment meeting the four criteria provided in subpara-
graphs (A) through (D) of that section. Accordingly, if any
portion of the payments made by petitioner fails to meet the four
enumerated criteria, that portion is not alimony and is not
deductible by petitioner.
Neither of the parties argues that the requirements of sub-
paragraphs (A), (B), and (C) of section 71(b)(1) have not been
satisfied. Their disagreement focuses on the provisions of
subparagraph (D). Section 71(b)(1)(D) requires that the payor
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