Dennis E. and Paula W. Lofstrom - Page 5

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          divorce decree.  Mr. Lofstrom stopped making payments sometime in           
          1995 and a year later asked a Minnesota county court to terminate           
          his alimony obligations because his salary had been substantially           
          diminished after retirement.  The State court instead found                 
          Mr. Lofstrom in arrears to Dorothy for the time that he failed to           
          pay alimony and reduced his arrearage to a judgment for $18,000.            
          The State court did grant Mr. Lofstrom a reduction, however, in             
          his monthly alimony payments from $1,500 to $1,000.                         
               Shortly thereafter, Dorothy agreed to relinquish her past              
          and future claims for alimony against Mr. Lofstrom in exchange              
          for $4,000 cash and Mr. Lofstrom’s interest in a contract for               
          deed valued at $29,000.  The contract for deed entitled Dorothy             
          to principal and interest payments until the principal was fully            
          paid.3  Payments under the contract for deed were to be made                
          irrespective of when Dorothy died.                                          
               Petitioners initially deducted as alimony only the $4,000              
          cash payment on their joint return for 1997.  They later amended            
          their return for 1997 and deducted the $29,000 value of the                 
          contract for deed.  Respondent granted petitioners the $4,000               
          deduction but denied the $29,000 deduction.                                 

               3The contract for deed was entered into between                        
          Mr. Lofstrom, as trustee of the Dennis Lofstrom Trust, and Mark             
          Lofstrom, the son of Mr. Lofstrom and Dorothy.  The contract for            
          deed required a $1,408.34 payment upon execution, $4,200 or more            
          annually at a rate of $350 monthly, and interest at a rate of 7.5           
          percent per year.                                                           






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