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under section 6662(a) for negligence in the respective amounts of
$609 and $708 for each year. Petitioner resided in Billings,
Montana, at the time the petition was filed.
The sole issue is whether amounts petitioner paid to or on
behalf of his ex-wife in 1994 and 1995 are deductible as alimony
under section 215.2
The facts may be summarized as follows. Petitioner was
married to Mieko Anderson (Ms. Anderson) from April 1967 until
June 1990. In 1970, Ms. Anderson began to suffer from mental
illness, and she became unpredictable and at times violent and
destructive. Over time Ms. Anderson's condition grew steadily
worse. She was diagnosed as schizophrenic. Petitioner filed for
divorce on June 13, 1990.
Ms. Anderson refused to participate in the divorce
proceedings, and the court appointed a conservator for her.
Although Ms. Anderson appeared to understand the nature of the
proceedings, she refused to comply with any of the court's
requests or attend any of the hearings. Ms. Anderson's
unwillingness to participate in the process prevented the court
from ascertaining her needs in terms of support. In addition,
Ms. Anderson's future was uncertain, i.e., whether or not she
would be institutionalized. Petitioner requested that the issue
of spousal support be reserved until the amount of support could
2 Respondent has conceded the accuracy-related penalties under
sec. 6662(a).
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