Memorandum Findings of Fact and Opinion
FAY, Judge:
Respondent determined a deficiency in petitioners' Federal income tax for the year 1962 in the amount of $1,398.28.
The only issue for determination is whether the amount of $6,500, paid by petitioner Robert P. Garvey to or for the benefit of his ex-wife, was properly deductible by him from gross income within the provisions of section 215 of the Internal Revenue Code of 1954.
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