Memorandum Opinion
DAWSON, Chief Judge:
Respondent determined a deficiency in petitioner's 1978 Federal income tax in the amount of $8,246. The case was submitted fully stipulated under Rule 122, Tax Court Rules of Practice and Procedure. The stipulated facts are so found and incorporated herein by this reference. The sole issue for decision is whether petitioner is entitled to an alimony deduction under section 215
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