Memorandum Findings of Fact and Opinion
The Commissioner determined a deficiency in petitioner's income tax for the year 1965 in the amount of $774.38. After concessions of the parties, the only issue is whether all or only part of petitioner's payments to his wife is deductible by him under section 215, I. R. C. 1954. This turns on whether effect should be given to a retroactive court order allocating a portion of petitioner's payments to his wife to child support...
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