Respondent determined a deficiency in income and victory tax for the year 1943 in the amount of $725.10. Respondent has included the sum of $3,600 in petitioner's income for each of the years 1942 and 1943, under the provisions of section 22 (k) of the Internal Revenue Code. Petitioner received these sums annually from her former husband, Frank M. Hesse, from whom she is divorced. The only question is
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