Memorandum Findings of Fact and Opinion
DAWSON, Chief Judge:
Respondent determined a deficiency of $25,328.47 in petitioners' Federal income tax for 1975. At issue is whether the value of an interest in property transferred to petitioner Eleanor M. Benson to satisfy unpaid obligations owed to her under a property settlement agreement and a divorce decree is taxable income in 1975 under sections 71
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