Toni L. Sarchett - Page 1















                                 T.C. Memo. 2007-180                                  


                               UNITED STATES TAX COURT                                


                           TONI L. SARCHETT, Petitioner v.                            
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      


               Docket No. 11785-06.             Filed July 9, 2007.                   


               Toni L. Sarchett, pro se.                                              
               Carolyn A. Schenck, for respondent.                                    


                       MEMORANDUM FINDINGS OF FACT AND OPINION                        

               COHEN, Judge:  Respondent determined a deficiency of $69,390           
          in petitioner’s Federal income taxes for 2004.  After a                     
          concession by respondent, the issue for decision is whether                 
          petitioner is entitled to deduct, as alimony under section 215,             
          $200,000 in payments made to her former spouse.  Unless otherwise           








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