In a case subject to the Bankruptcy Act and a case subject to the Bankruptcy Code, the court considered the collateral estoppel effect of a divorce decree on the issue of "alimony, maintenance or support," as well as whether the court should consider the parties' financial circumstances subsequent to entry of the decree, concluding that what constitutes alimony, maintenance or support for purposes of non-dischargeability is a matter of federal law, although a duty of support is dependent on state law. Bankruptcy courts must look behind the language used in the decree to determine whether a provision is actually in the nature of support. Moreover, bankruptcy courts must consider whether an award in the nature of support is still reasonably necessary for support at the time of discharge in bankruptcy.