§1881

alysis. 5(...continued) 1812(c), 100 Stat. 2834. Both were effective retroactively to taxable years beginning after Dec. 31, 1983. Deficit Reduction Act of 1984, Pub. L. 98-369, sec. 174(c), 98 Stat. 707-708; Tax Reform Act of 1986, Pub. L. 99-514, sec. 1881, 100 Stat. 2914. - 18 - In this step, we defer to the agency's choice between "conflicting reasonable interpretations" of the statute. Holly Farms Corp. v. NLRB, 517 U.S. at 398-399. We examine, inter alia, legislative history in the second

ayment after the death of the payee spouse. That requirement was deleted by the technical corrections provisions of the Tax Reform Act of 1986 (TRA 86), Pub. L. 99-514, sec. 1843(b), 100 Stat. 2853, retroactive to the effective date of DEFRA, TRA 86 sec. 1881, 100 Stat. 2914. See also Notice 87-9, 1987-1 C.B. 421, 422. Hence, the divorce or separation instrument need not expressly state that the payment obligations terminate upon the death of the payee spouse if, for example, termination would o

ayment after the death of the payee spouse. That requirement was deleted by the technical corrections provisions of the Tax Reform Act of 1986 (TRA 86), Pub. L. 99-514, sec. 1843(b), 100 Stat. 2853, retroactive to the effective date of DEFRA, TRA 86 sec. 1881, 100 Stat. 2914. See also Notice 87-9, 1987-1 C.B. 421, 422. Hence, the divorce or separation instrument need not expressly state that the payment obligations terminate upon the death of the payee spouse if, for example, termination would o