Gerald Barlow - Page 3

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               Respondent determined a deficiency of $5,214 in petitioner’s           
          Federal income tax for 2000.  The sole issue for decision is                
          whether payments of $23,3781 petitioner made to his former spouse           
          during the year in issue were properly deductible as alimony.               
               Some of the facts have been stipulated, and they are so                
          found.  The stipulation of facts and the attached exhibits are              
          incorporated by this reference.  At the time of filing the                  
          petition, petitioner resided in Lakeland, Florida.                          
               Petitioner and his former wife divorced on July 15, 1991,              
          after 37 years of marriage.  Their divorce proceedings were                 
          adjudicated by the Circuit Court of Polk County, Florida (Florida           
          circuit court).                                                             
               In a Final Judgment of Dissolution of Marriage (divorce                
          decree), dated July 15, 1991, the Florida circuit court ordered             
          an equitable distribution of marital assets and awarded alimony             
          to petitioner’s former wife.  As relevant to this discussion, the           
          equitable distribution of marital assets included a provision               
          addressing the division of petitioner’s retirement plan                     

               1 All amounts have been rounded to the nearest dollar.                 

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