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OPINION
LARO, Judge: This case is before the Court for decision
without trial. See Rule 122.1 Petitioners petitioned the Court
to redetermine a $7,031 deficiency in their 2000 Federal income
tax. We decide as to that year whether petitioners may deduct as
alimony $21,600 that John R. Okerson (petitioner) paid pursuant
to his divorce from his former wife, Barbara Buhr Okerson
(Okerson). We hold that petitioners may not deduct any of that
amount.
Background
The facts in this background section are obtained from the
parties’ stipulation of facts and the exhibits submitted
therewith. Petitioners resided in Memphis, Tennessee, when their
petition was filed. Petitioner and his former wife, Okerson,
have two children who were born on February 10, 1978, and
April 3, 1983, respectively.
On August 31, 1994, a Tennessee State court (State court)
issued an order awarding Okerson a divorce from petitioner. On
March 13, 1995, the State court entered a supplemental final
decree of divorce (1995 decree) that in relevant part ordered,
adjudged, and decreed as follows:
1 Rule references are to the Tax Court Rules of Practice and
Procedure. Unless otherwise stated, section references are to
the applicable versions of the Internal Revenue Code.
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Last modified: May 25, 2011