Memorandum Findings of Fact and Opinion
COHEN, Judge:
Respondent determined deficiencies of $5,168 and $5,584 in Petitioner Esther L. Houston's income taxes for 1978 and 1979, respectively, and deficiencies of $2,047 and $5,427 in Petitioner Donald E. Houston's income taxes for 1978 and 1979, respectively. After concessions, the issue remaining for decision in these consolidated cases is whether payments made by Esther to Donald pursuant to a divorce and...
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