Renee B. Simpson - Page 13




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          half reduced Mr. Simpson's own obligation and were not made on              
          petitioner's behalf.                                                        
          Home Equity Loan                                                            
               We now turn to the issue of whether the $142 monthly                   
          payments toward the home equity loan constitute alimony to                  
          petitioner.  The full home equity loan monthly payment was $474,            
          which Mr. Simpson paid in full each month.  Out of this amount,             
          the court order required Mr. Simpson to allocate a portion of the           
          total amount due, or $142, to be paid on petitioner's behalf.               
               A portion of the loan proceeds was used to finance the                 
          purchase of a Buick Regal by Mr. Simpson in 1989 and retained by            
          him after he and petitioner separated.  The remaining portion of            
          the loan proceeds was attributable to joint credit card debt                
          accrued before he and petitioner separated in 1990.  It is for              
          this portion of the debt that the family court ordered                      
          Mr. Simpson to pay $142 on petitioner's behalf.                             
               As previously stated, payments are alimony to the extent               
          they satisfy an obligation of petitioner.  See Taylor v.                    
          Commissioner, supra.  We find no significant difference between             
          the payments made on petitioner's behalf toward the marital                 
          mortgage and the payments made on petitioner's behalf toward the            
          home equity loan.  In both instances, the debt was secured by the           
          marital home, and petitioner and Mr. Simpson are jointly liable             
          to the lender for the payment due each month.  Mr. Simpson made             





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