Memorandum Findings of Fact and Opinion
FAY, Judge:
Respondent determined deficiencies in the income tax liability of petitioner for the taxable years 1967 and 1968 in the respective amounts of $412.66 and $3,130.19. The issues for resolution are (1) whether amounts paid by petitioner to his former wife pursuant to a divorce decree qualify as periodic payments under section 71(a)(1) of the Internal Revenue Code of 1954
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