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tax deductible to the petitioner, and taxable to the
respondent [Ms. Eads] on their respective federal and
state income tax returns. * * *
For the taxable years at issue, Ms. Eads included the following
payment amounts as alimony on her Federal income tax returns:
$7,250 in 1992, $7,250 in 1993, $7,200 in 1994, and $3,199 in
1995. Petitioner agrees that these are the amounts he actually
paid.
Petitioner was divorced from his second wife, Ms. Susan
Tang, in May 1989. He was required to pay $400 per month in
"family support". Petitioner had an "agreement in principle"
with Ms. Tang that she would include the payments to her as
income on her Federal income tax return, and petitioner would
claim a deduction for these payments on his Federal income tax
return.
Petitioner was not married at the end of taxable years 1992
and 1993; however, petitioner was married at the end of taxable
years 1994 and 1995. Petitioner's third wife has two daughters.
OPINION
Petitioner has the burden of proof with regard to all the
issues raised in this case. See Rule 142(a).
Issue 1. Whether Petitioner Is Entitled to Alimony Deductions
During the Years in Issue
In this case, petitioner made "family support" payments to
both Ms. Eads and Ms. Tang. Petitioner claims that the amounts
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