Nathan and Maranda agree to divorce in the current year. In structuring the divorce agreement, Maranda proposes that Nathan assign a $200,000 life insurance policy on himself to her as part of the divorce agreement. Under Maranda’s proposal, Nathan would continue paying the premiums on the life insurance policy. Nathan’s attorney, Horace, has asked you to determine whether the insurance premium payments would be considered an alimony payment made by Nathan. Determine the tax treatment of the proposed premium payments and write a memorandum to Horace summarizing your results.