Renee B. Simpson - Page 14




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          the entire home equity loan payment of $474 each month and                  
          therefore had a right of contribution from petitioner of one-               
          half, or $237.  See Taylor v. Commissioner, supra.  The family              
          court ordered that Mr. Simpson pay, on petitioner's behalf, a               
          lesser amount of $142 each month toward this obligation, and we             
          find that amount to be alimony to her.                                      
               The record reflects that the home equity loan was paid off             
          before 1995.  Petitioner offered no evidence to show how many               
          payments were made in 1994.  Accordingly, we find that the $142             
          alimony payments were made through the entire taxable year 1994.            
               To reflect the foregoing,                                              
                                             Decision will be entered                 
                                        under Rule 155.                               
























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