Toni L. Sarchett - Page 6




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          continue without regard to the death of petitioner’s former                 
          spouse.  Thus the payments are not deductible as alimony.                   
               Petitioner argues that the payments would terminate on death           
          under State law because they are alimony.  There is no persuasive           
          evidence that the payments were alimony, however.  The evidence             
          is to the contrary, and there is no need to resort to State law             
          to determine the character of the payments.                                 
               We have considered the other arguments of the parties, and             
          they are irrelevant to our decision.  To reflect respondent’s               
          concession,                                                                 

                                                  Decision will be entered            
                                             under Rule 155.                          

























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