Court denies alimony deduction for lump-sum pension payment after divorce

Ditullio v. Commissioner, T.C. Memo. 2025-120, No. 4049-23. BL 412469.

A one-time $50,000 payment tied to pension benefits failed the alimony rules because the obligation did not clearly end at the ex-spouse’s death.

Holding

The Tax Court held that a $50,000 lump-sum payment made to an ex-wife was not alimony under §71(b)(1) and therefore was not deductible under §215(a). The IRS deficiency was sustained. The accuracy-relate…