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of section 71. It is not the Court’s place to support
respondent’s attempt to include language Congress itself did not.
Accordingly, we hold that, under the unique facts of this
case, petitioner’s payments made to his ex-wife in 2002 satisfied
the conditions set forth in section 71 and were thus properly
deductible as alimony for that taxable year.
To reflect our disposition of the disputed issue, as well as
respondent’s concession,
Decision will be entered
for petitioner.
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Last modified: November 10, 2007