Memorandum Findings of Fact and Opinion
SIMPSON, Judge:
The Commissioner determined deficiencies in the petitioner's Federal income taxes of $8,002.20 for 1977 and $52,745.82 for 1979. After concessions, the only issue remaining for our decision is whether periodic payments made by the petitioner to his former wife pursuant to a divorce decree are deductible under section 215, Internal Revenue Code of 1954,
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