Payments now satisfy § 71(b)(1)(D) when the divorce order is silent if background principles of state law mandate that the payments necessarily terminate upon the death of the payee spouse. See generally Hoover v. Comm’r, 102 F.3d 842, 845-47 (6th Cir.1996); Zinsmeister v. Comm’r, 80 T.C.M. (CCH) 774 (2000). Because neither the temporary orders nor the permanent orders in this case expressly state whether Lovejoy’s obligations would continue in the event his ex-spouse died, we look to Colorado law. Colorado has adopted the Uniform Dissolution of Marriage Act (“UDMA”), which states that “[u]nless otherwise agreed in writing or expressly provided in the decree, the obligation to pay future maintenance is termi r. 14, 1996) (same), with Wells v. Comm’r, 75 T.C.M. (CCH) 1507 (Jan. 5, 1998) (<HOLDING>). This split of authority interpreting
holding where a defendant successfully challenges a conviction on appeal jeopardy does not terminate holding that the obligation to pay unallocated support would automatically terminate upon the recipients death holding that the obligation does not terminate upon death holding that custodial parents death does not terminate noncustodial parents child support obligations set forth in dissolution decree holding that insurance obligation was primary to indemnity obligation