OPINION
COHEN, Judge:
Respondent determined deficiencies in petitioners' 1987 Federal income tax of $384,792 for Arthur C. Hawkins (Dr. Hawkins) and $377,573 for Glenda R. Hawkins (Mrs. Hawkins). These deficiencies stem from payments made to Mrs. Hawkins from the Arthur C. Hawkins, D.D.S., P.A. Pension Plan (pension plan), in connection with her divorce from Dr. Hawkins. These consolidated cases are before the Court on the parties' cross-motions for...
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