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marital home and divisions of various marital property. However,
the language of the Settlement Agreement belies petitioner’s
position; Barbara waives her rights to alimony in exchange for
the “pension payment and benefits as herein set forth” and in
context these “benefits” refer to the health insurance and
automobile fringe benefits that are outlined immediately before.
To the extent the payments relieved Walter of his obligation
to pay alimony, they are nondeductible by petitioner. A
corporation’s payment of its shareholder’s personal expense or
obligation is not deductible by the corporation. See Greenspon
v. Commissioner, 229 F.2d 947 (8th Cir. 1956), affg. in part and
revg. in part 23 T.C. 138 (1954); Enoch v. Commissioner, 57 T.C.
781 (1972); American Properties, Inc. v. Commissioner, 28 T.C.
1100 (1957), affd. per curiam 262 F.2d 150 (9th Cir. 1958). This
Court has found in circumstances similar to the present ones that
payments made by a closely held corporation to the former spouse
of a controlling shareholder and claimed as deductible
compensation or other business expense were disguised alimony or
part of a property settlement and therefore nondeductible
personal expenditures of the shareholder. See J.B.S. Enters.,
Inc. v. Commissioner, T.C. Memo. 1991-254; Greenwood v.
Commissioner, T.C. Memo. 1989-368; Frankland Racing Equip., Inc.
v. Commissioner, T.C. Memo. 1987-210. These cases concerned
situations where the shareholder’s spouse had at no time rendered
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