OPINION.
KERN, Chief Judge:
Respondent determined deficiencies in petitioners' income tax liability for the years 1951 and 1952 in the amounts of $663 and $988, respectively, by reason of his disallowance of deductions claimed as alimony payments in the amount of $1,700 for the year 1951, and $2,600 for the year 1952. The returns were filed with the director of internal revenue for the western district of New York. In the petition petitioners alleged...
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