Mark E. Picou - Page 11

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          sold).  Indeed, the payments served only to increase the value of           
          the Lakewood home, which benefit inured exclusively to petitioner           
          as the sole owner.  See Stiles v. Commissioner, T.C. Memo. 1981-            
          711.                                                                        
               Under the facts and circumstances of this case, we conclude            
          that the mortgage payments do not constitute alimony.                       
          Accordingly, we sustain respondent’s determination.                         
                                     Conclusion                                       
               Reviewed and adopted as the report of the Small Tax Case               
          Division.                                                                   
               To reflect our disposition of the disputed issue, as well as           
          petitioner’s concession, see supra note 2,                                  


                                             Decisions will be entered                
                                        for respondent.                               




















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