OPINION
THORNTON, District Judge.
This is a tax refund case. Cross motions for summary judgment have been filed by the parties. They have been submitted to the Court for determination on the basis of a Stipulation of Facts filed herein, briefs and oral argument. At issue is the question whether certain transfers of General Motors shares of stock by plaintiff to his ex-wife pursuant to the terms of a decree of divorce are to be categorized as alimony or as...
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