Curtis L. Anderson - Page 2




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          $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            
          be determined.  The Judgment Of Dissolution Of Marriage provided            




          2   Respondent has conceded the accuracy-related penalties under            
          sec. 6662(a).                                                               

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