Memorandum Findings of Fact and Opinion
DAWSON, Judge:
Respondent determined a deficiency in petitioner's income tax for the year 1962 in the amount of $2,185.08. The issues we must decide are (1) whether $2,500 of a $27,500 divorce property settlement constitutes a lump sum payment of alimony in arrears which is deductible under section 215, Internal Revenue Code of 1954,
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