Memorandum Opinion
RICE, Judge:
This proceeding involves a deficiency in income tax for the year 1947 in the amount of $966.25.
The sole issue is whether $3,000 of a $12,500 payment received by decedent at the time of her divorce was taxable as a periodic payment of alimony within the meaning of section 22(k) of the 1939 Code.
[Findings of Fact]
All of the facts were stipulated, are so found, and are incorporated herein by...
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