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regulations and imposed a section 6662(a) accuracy-related
penalty. Other adjustments made in the notice of deficiency are
computational and need not be addressed.
Discussion
1. Alimony Deduction
Petitioner claimed a $7,800 alimony deduction on his 2002
return. As best can be determined from the record, this amount
represents petitioner’s estimate of how much of the $15,480
withheld from his wages and presumably paid to his former
spouse is allocable to other than child support, which
petitioner recognizes is not deductible as alimony. See secs.
71(c), 215. According to respondent, the entire amount
represents child support, and no portion is deductible as
alimony.
It appears that the amount petitioner deducted as alimony
in some way or another is traceable to mortgage payments on the
marital residence that petitioner was required to make directly
to his former spouse after he separated from her.3 Although we
fail to fully comprehend petitioner’s position, we do not
hesitate to reject it for the simple reason that he made no
mortgage payments, directly or indirectly, on the marital
residence during 2002. The marital residence was foreclosed
3 For a discussion on this point, see, e.g., Grutman v.
Commissioner, 80 T.C. 464 (1983).
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