Memorandum Findings of Fact and Opinion
MULRONEY, Judge:
Respondent determined a deficiency in petitioner's income tax for 1961 and 1962 in the respective amounts of $1,541.75 and $211.54. The issues are (1) whether certain payments received by petitioner in 1961 and 1962 are includable in her income as alimony under section 71 of the Internal Revenue Code of 1954,
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