Nada Nahhas - Page 12

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          and are not allowable as a deduction to Mr. Nahhas.  Richardson             
          v. Commissioner, supra at 556.                                              
               Petitioner argues that the payments were always intended to            
          be nontaxable child support.  To support her contention,                    
          petitioner presented testimony at trial that the dollar amounts             
          provided for in the temporary order were based on guidelines set            
          forth under State law for child support.  In addition,                      
          petitioner’s attorney during the marital dissolution proceedings            
          testified at length that he intended that the payments under the            
          temporary order to be for child support and, hence, nontaxable to           
               The Court concludes that the payments do not qualify as                
          child support under section 71(c)(1).                                       
               Thus, petitioner received alimony under the temporary order            
          in 2002 in the amount of $118,800.  ($13,200 per month x 9                  
          II.  Interest Income                                                        
               Generally, gross income means all income from whatever                 
          source derived, including interest income.  Sec. 61(a)(4).                  
          During 2002, respondent received information from third-party               
          payers that petitioner received interest income from three                  

               5 Petitioner’s attorney evidently drafted the temporary                
          order after a hearing and at the direction of the circuit court.            
          Upon review, the circuit court adopted the temporary order.                 

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