Kahn: "Alimony Treatment for a Single Payment"

Douglas A. Kahn (University of Michigan Law School) recently posted Alimony Treatment for a Single Payment, 125 Tax Notes__ (2009), on SSRN.  Here is the abstract:  

The author concludes that, contrary to the IRS and the Tax Court’s position, a single lump sum payment to a divorced spouse can qualify for alimony treatment in some circumstances subject to the front-loading rules. The author also contends that to conform to the requirement of the alimony provision, a payment of a divorced spouse’s legal or medical expenses under a divorce or separation instrument should qualify for alimony treatment even though those payments usually will not satisfy the literal terms of the statute.

MR