GOLDBERG, Circuit Judge:
If it is true that an unhappy marriage is a zero-sum game, it is no less true that the financial arrangements incident to the marriage's dissolution perpetuate that game. And when a marriage made in heaven plummets to earth, the postlapsarian ceremonies are presided over by that most fallen of angels, the Commissioner of Internal Revenue. In this case we must decide whether payments made by David Stock to his former wife, Shara, were periodic...
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