Memorandum Findings of Fact and Opinion
BRUCE, Judge:
Respondent has determined deficiencies in income tax against the petitioner for the calendar years 1946 and 1947 in the respective amounts of $263.33 and $257.25.
The issue presented is whether $1,200 received by the petitioner in each of the taxable years from her former husband is includible in her gross income pursuant to section 22 (k), Internal Revenue Code.
Findings of Fact
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