M. Jay Steen and Sheila F. Steen v. Commissioner of Internal Revenue

JOHN R. GIBSON, Circuit Judge.

M. Jay Steen and Sheila F. Steen appeal from a decision of the tax court 1 determining deficiencies in their joint federal income tax returns for the years 1982 and 1983. The deficiencies resulted because Jay and his present wife, Sheila, claimed alimony deductions for certain payments to Jay’s former wife, Janet. The tax court determined that these payments were in the nature of a property settlement, not alimony, and thus were not deductible under 26 U.S.C. § 215 (1982). 2 We affirm the judgment of the tax court.

Jay and Janet Steen were divorced in 1978. At…