Memorandum Opinion
BRUCE, Judge:
Respondent determined a deficiency in the income tax of petitioner for the year 1961 in the amount of $293.23. The issue is whether monthly payments in the total amount of $4,112.20 which were received by petitioner in 1961 pursuant to a separation agreement were periodic payments of alimony and therefore includable in their entirety in her gross income. An issue raised in the petition pertaining to respondent's disallowance...
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