MEMORANDUM OPINION
GOEKE, Judge:
Respondent determined a deficiency in petitioner's 1996 Federal income tax of $20,394. The sole issue for decision is whether a payment of $50,000 petitioner made to his ex-wife in 1996 is deductible as alimony under section 215(a).
Background
The parties submitted this case fully stipulated pursuant to Rule 122. The stipulation of facts and the attached exhibits are...
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