John Okerson (plaintiff) was obligated to make alimony payments to his ex-wife pursuant to a divorce decree. The decree provided that Okerson would make payments to his ex-wife and that these payments would go toward their children’s education if the ex-wife died. Okerson’s ex-wife remained alive during all relevant payments. Okerson claimed an alimony deduction for these payments on his federal taxes. The commissioner of internal revenue (commissioner) (defendant) disallowed the alimony deduction. Okerson petitioned the United States Tax Court for a redetermination.