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of it. Initially, we note that petitioner’s claim in this regard
is not, as a technical matter, entirely correct. Although we
cannot tell exactly how much, a substantial part of the proceeds
from the sale of the townhouse was used to satisfy the debt that
petitioner incurred at the time that she and her former spouse
purchased it. Payment to a taxpayer’s creditor on the taxpayer’s
behalf is tantamount to payment to the taxpayer. See Old Colony
Trust Co. v. Commissioner, 279 U.S. 716, 729 (1929); Poczatek v.
Commissioner, 71 T.C. 371, 378 (1978). In this case, despite the
reprehensible conduct of petitioner’s former spouse in connection
with the net proceeds from the sale of the townhouse, the
economic benefit petitioner enjoyed in the form of debt reduction
cannot be ignored. See Sowell v. Commissioner, 302 F.2d 177,
180-181 (5th Cir. 1962); Urbauer v. Commissioner, supra.
Furthermore, the fact that petitioner did not receive any of
the proceeds of the sale of the townhouse immediately after its
sale, was due, at least in part, to petitioner’s conduct.
Although we sympathize with her, it remains that it was her
choice not to attend the settlement. Petitioner did not explain
why she elected not to attend the settlement. Perhaps it was
inconvenient for her to travel from the location where she was
living at the time to the location where the settlement was
conducted. Nevertheless, she could have attended the settlement
and ensured the receipt of the sale proceeds to which she was
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