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Cheryl J. Lovejoy (Ms. Miller), for the taxable years 1993 and
1994 of $8,863 and $2,766, respectively. Respondent also
determined deficiencies in the Federal income tax of petitioner
John H. Lovejoy (Mr. Lovejoy) for the taxable years 1993 and 1994
of $12,018 and $5,905, respectively.
These cases have been consolidated for purposes of trial,
briefing, and opinion because they involve common questions of
fact and law arising from the separation and divorce of
petitioners. After concessions,1 the issues addressed in this
opinion are:
(1) Whether any part of "unallocated child support and
maintenance" payments made pursuant to a State court decree is
alimony deductible by the payor spouse under section 2152 and
includable in the income of the payee spouse under section 71;
and
1Mr. Lovejoy has conceded that a State tax refund of $175 is
includable in his gross income for the taxable year 1993.
Respondent has conceded that Ms. Miller is entitled to claim
additional medical expenses for the taxable year 1993 in the
amount of $1,033 before application of the limits of sec. 213(a).
2Unless otherwise indicated, all section references are to
the Internal Revenue Code, as in effect for the taxable years in
issue, and all Rule references are to the Tax Court Rules of
Practice and Procedure. All monetary amounts are rounded to the
nearest dollar.
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