§3105

3105.18(B)(LexisNexis 2008); see also Hoover v. Commissioner, 102 F.3d at 844-847; Heffron v. Commissioner, T.C. Memo. 1995-253, aff'd withoutpublished opinion sub nom. Murley v. Commissioner, 104 F.3d 361 (6th Cir. 1996); Meeks v. Meeks, 2006 WL 328685 (Ohio Ct. App. Feb. 14. 2006). Section 71(c), however, goes on to provide that alimony trea

2008-207; see also Hoover v.

If Congress had intended to assign CDP duty to a particular rank of "Appeals officer", it would not have added the phrase "or employee" ; and it could have used language like that which it used simultaneously in RRA section 3105 where it provided that a bond issuer could appeal an adverse ruling "to a senior officer of the Internal Revenue Service Office of Appeals" .

3105.171(A)(3)(a) (Anderson 2000).2 Respondent’s reliance on Berish 2 Ohio Rev. Code Ann. sec. 3105.171(A)(3) (Anderson 2000) (continued...) 7 2(...continued) provides as follows: 3105.171 Equitable division of marital and separate property; distributive award * * * * * * * (3)(a) “Marital property” means, subject to division (A)(3)(b) of thi

3105.18(B) (Anderson 1996), and predecessor sections. Having decided that the $60,000 constitutes alimony within the meaning of section 71, we must address Ms. Burkes' secondary argument that she did not receive any of the $60,000 in attorney's fees until 1991. In that regard, Mr. Burkes deducted $55,636 as alimony, representing attorney's fee