Robert L. Stahl - Page 15




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                    (e) $1,000.00 – from the MacDill Credit Union;                    
               and,                                                                   
                    (f) $655.00 – cash from Husband.                                  
               It is unclear what the State Court meant by “the parties’              
          assets”.  To the extent Ms. Hodson received payments from assets            
          in which she had an ownership interest, those payments, to the              
          extent liquidating that interest, were not alimony to her.  See             
          Jaffe v. Commissioner, T.C. Memo. 1999-196.  Petitioner has                 
          failed to convince us that he complied with the July 1, 1994,               
          order other than that Ms. Hodson received $2,125.73 from the                
          MacDill Federal Credit Union.  Petitioner has failed to convince            
          us that his interest in that account was more than $1,000.  To              
          that extent, however, we find that he paid alimony to Ms. Hodson            
          during 1994.                                                                
               C.  Conclusion                                                         
               Petitioner is entitled to a deduction for alimony paid                 
          during 1994 of $1,000.                                                      
          III.  1995 Adjustments                                                      
               A.  Alimony                                                            
               Petitioner claims that, during 1995, pursuant to the                   
          September 8, 1994, order, he made five monthly payments of                  
          alimony (from January through May), each in the amount of $2,500.           
          For the same reasons as with respect to 1994, petitioner has                
          failed to prove that, during 1995, he made any of the monthly               
          payments required by the September 8, 1994, order.                          





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