Respondent determined a deficiency in petitioner's income tax of $9,377 in the taxable year 1973 and of $3,491 in the taxable year 1974.
Due to a concession by petitioner, the only issue remaining for our decision is whether payments from petitioner to his former wife during 1973 and 1974, pursuant to a final judgment of divorce in 1972, are deductible either as alimony under section 215
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