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settlement, a final settlement agreement would have been reached
before April 17, 1989, and the 10-year term of the “alimony”
payments would not have expired within 6 months of Julie’s 18th
birthday. We thus conclude that the payments at issue are
alimony and includable in petitioner’s income.
To reflect the foregoing,
Decision will be entered for
respondent for the deficiencies in tax
and for petitioner for the penalties
under section 6662(a).
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