S.E.2d 161, 164 (1994) (whether a payment is spousal support and maintenance or a property distribution is determined by the function that payment is intended to serve). See also In re Zuccarell, 181 B.R. 42, 44-45 (Bankr.N.D.Ohio 1995) (recognizing that, typically, a property division is not affected by a change in the personal circumstances of the recipient spouse); In re Ackley, 186 B.R. 1005, 1010 (Bankr.N.D.Ga.1994) (noting that the structure of a provision — whether payment is lump sum or periodic, method of payment, terms of payment, amount of payment, whether payment is modifiable, and whether payment is subject to contingencies — is an important element in determining whether the provision is one for support or a property division); In re Edwards, 162 B.R. 83, 85 (D.Conn.1993) (<HOLDING>); In re Jensen, 17 B.R. 537, 540
holding that an obligation is in the nature of alimony when it is intended to provide support for the spouse rather than an equalization of property rights holding that property transferred by a spouse to avoid support obligation may be considered on the issue of property distribution as well as alimony holding that a spouse is not necessarily an agent of the debtor holding that payments in the nature of support need not be made directly to the spouse or dependent to be nondischargeable recognizing that family court may under special circumstances require a supporting spouse to secure an alimony obligation with a life insurance policy