OPINION
FORRESTER, Judge:
The respondent has determined a deficiency in the petitioner's Federal income tax for 1959 in the amount of $7,205.35.
The only issue for our consideration is whether royalties in the amount of $21,406.74 are fully taxable to the petitioner as alimony or whether such payments are gifts, or are bequests subject to depreciation. Another issue raised by the pleadings has been conceded by the respondent.
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