CUNNINGHAM v. COMMISSIONER

Docket Nos. 22738-91, 12460-92.

68 T.C.M. 801 (1994)

T.C. Memo. 1994-474

Mark Cunningham and Linda Cunningham v. Commissioner.

United States Tax Court.

Filed September 29, 1994.


Attorney(s) appearing for the Case

Joseph B. Hurst, Jr., Walter M. Ebel III, John Ray White, and T. Wesley Holmes, 400 W. Capitol, Little Rock, Ark., for the petitioners. Elizabeth S. Simmons, for the respondent.


Memorandum Findings of Fact and Opinion

BECHE, Judge:

Respondent determined deficiencies of $11,550, $8,400, and $9,900.08 in petitioners' Federal income tax for 1987, 1988, and 1989, respectively.

The sole issue for decision is whether petitioners Mark and Linda Cunningham are entitled to deduct Mark's monthly payments to his ex-wife, Shirley Cunningham, as alimony. Specifically, if Shirley were to die before Mark had made the 142 payments called...

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