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all Rule references are to the Tax Court Rules of Practice and
Procedure. The decisions to be entered are not reviewable by any
other court, and this opinion should not be cited as authority.
Respondent determined for 2002 a deficiency in the Federal
income tax of petitioners, John R. Ray IV (Mr. Ray) and Rochelle
L. Ray, in the amount of $16,210. Respondent also determined for
2002 a deficiency in the Federal income tax of petitioner Jennie
S. Ray, now known as Jennie S. Bader (Ms. Bader), in the amount of
$11,391.
These cases have been consolidated for purposes of trial,
briefing, and opinion, because they involve common questions of
fact and law arising from the separation and divorce of Mr. Ray
and Ms. Bader.
The issue for decision is whether certain payments made by
Mr. Ray to Ms. Bader in 2002 constitute alimony payments within
the meaning of section 71(b)(1) that are deductible by Mr. Ray
under section 215(a) and that are includable in the income of Ms.
Bader under section 71(a).
Background
The stipulation of facts and the exhibits received into
evidence are incorporated herein by reference. When the petitions
in these cases were filed, Mr. Ray resided in Spring, Texas, and
Ms. Bader resided in Tomball, Texas.
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