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that the $47,900 payment is not alimony and instead represents a
nontaxable division of marital assets.
We hold that petitioners may not deduct the $47,900 payment
as alimony. We have considered all arguments for a contrary
holding and find that it is unnecessary to reach them or that
they are without merit.
Decision will be entered
for respondent.
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Last modified: May 25, 2011