§11051

It is unclear whether the Consent Order, which was executed after December 31, 2018, was a modification of the FJOD as that term is used in TCJA § 11051(c)(2) or merely an implementation of the parties’ agreement in the FJOD. However, even if the Consent Order was a modification of the FJOD, it does not expressly provide that the amendments made by TCJA § 11051 apply to the Consent Order. Thus, the repeal does not apply to this case.

11051, 131 Stat. at 2089-2090, alimony paid is no longer deductible ifpaid pursuant to a divorce instrument executed after December 31, 2018. That statutory change does not apply to the tax yearbefore the Court.

2054, 2089–90. That law generally eliminated the alimony deduction in the case of divorce or separation agreements executed after December 31, 2018. See id. During the tax years at issue section 215(a)1 allowed a deduction for “alimony or separate 1 Unless otherwise indicated, statutory references are to the Internal Revenue Code

115-97, § 11051(b)(1), 131 Stat.

115-97, § 11051(b)(1), 131 Stat.

2054, 2089. This repeal does not affect this case. 4 (A) such payment is received by (or on behalf of) a spouse under a divorce or separation instrument, (B) the divorce or separation instrument does not designate such payment as a payment which is not includible in gross income under this section and not allowable as a deductio

2054, 2089. That repeal does not affect this case. 5 [*5] 205 F.3d 1333 (4th Cir. 2000); see also Aames v. Commissioner, 94 T.C. 189, 192–93 (1990) (explaining that because interest compensates for delay in the receipt of funds, interest awarded in a judgment is generally taxable regardless of how the judgment principal is, or i

2054, 2089. Both the agreement and the amended agreement dated September 17, 2016, and May 11, 2017, respectively, are unaffected by this repeal as they were executed before December 31, 2018 (and not modified thereafter). 7 separation instrument does not designate the payment as a payment that is not includible in gross income

2054, 2089. This repeal does not affect this case. 4 [*4] (2) Treatment of certain reductions related to contingencies involving child.—For purposes of paragraph (1), if any amount specified in the instrument will be reduced— (A) on the happening of a contingency specified in the instrument relating to a child (such as attaining

11051, 131 Stat. at 2089. The 2014 agreement is unaffected by this repeal as it was executed before December 31, 2018 (and not modified thereafter). - 7 - clear declaration of congressional intent.” Thrifty Oil Co. & Subs. v. Commissioner, 139 T.C. 198, 205 (2012); accord United States v. Skelly Oil Co., 394 U.S. 678, 684 (1969); Charles Ilfe

11051(b)(1)(A), 131 Stat. at 2089, redesignated sec. 61(a)(11) as sec. 61(a)(10) for taxable years beginning after December 31, 2018. - 7 - declaration, copy ofa check, and Form 1099-R provided by Northern Trust show that petitioner received $86,400 in taxable retirement income in 2016, rather than the $45,025 reported on his return. Petition