Memorandum Findings of Fact and Opinion
STERRETT, Judge:
Respondent determined deficiences in petitioners' Federal income taxes for the calendar years 1972 and 1973 in the amounts of $2,803 and $4,897, respectively. The sole issue for decision is whether amounts paid by petitioner Sheldon A. Bernstein to his former wife, pursuant to a divorce decree, are periodic payments under section 71(a)(1), I.R.C. 1954, and are therefore deductible by him under section...
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