FAY, Judge:
Respondent determined a deficiency in petitioners' Federal income tax for the taxable year ending December 31, 1969, in the amount of $4,369.
The sole issue presented for our determination is whether amounts paid by petitioner George B. Kent, Jr., to his former wife, pursuant to a divorce decree, qualify as periodic payments within the provisions of section 71(a) (1) of the Internal Revenue Code of 1954,
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