Memorandum Findings of Fact and Opinion
Respondent determined deficiencies in income tax against petitioner for the years 1952 and 1953 in the respective amounts of $280.34 and $274.48. The issue involved in this proceeding is whether amounts received by petitioner from her former husband in the taxable years constituted alimony taxable to petitioner under section 22(x) of the Internal Revenue Code of 1939, or constituted sums "payable for the support of minor children...
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