Memorandum Opinion
SWIFT, Judge:
Respondent determined a deficiency in petitioner's income tax for 1978 in the amount of $64,969.37. The parties have reached a partial settlement and the only issue for the Court to decide is whether the transfer of certain lots of real estate to petitioner's former wife in connection with their divorce in 1978 constitutes a deductible alimony payment under section 215.
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