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the extent set forth below. Unless otherwise indicated, all
section references are to the Internal Revenue Code in effect for
the taxable years in issue, and all Rule references are to the
Tax Court Rules of Practice and Procedure.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulated facts and the accompanying exhibits are
incorporated herein by this reference. At the time
the petition in this case was filed, petitioner resided in
Rochester, Minnesota.
Petitioner and Betty J. Zinsmeister (Betty) were married in
1974. In 1986, they took out a mortgage (the first mortgage) on
their jointly owned residence in the principal amount of $77,900.
Petitioner and Betty were jointly liable on the first mortgage
note.
Betty initiated divorce proceedings against petitioner in
August 1991 and, in October, moved out of the residence. Two of
their three children moved with her, and the third remained with
petitioner.
On October 17, 1991, the District Court for the Third
Judicial District of Minnesota - Family Division (the State
court) issued a temporary order. Therein, under the heading
"Support of the Minor Children", the State court set petitioner’s
monthly child support obligation at $950. In addition,
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