Memorandum Findings of Fact and Opinion
MULRONEY, Judge:
The respondent determined deficiencies in petitioner's income tax for the years 1957 and 1958 in the amounts of $180 and $261.32, respectively.
The issue is whether certain sums paid to petitioner pursuant to a decree of divorce were periodic payments and thus fully taxable to petitioner under the provisions of section 71, Internal Revenue Code of 1954.
Findings of Fact
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