Memorandum Findings of Fact and Opinion
DRENNEN, Judge:
Respondent determined deficiencies in petitioners' Federal income taxes for the taxable years ended December 31, 1972, and December 31, 1973, in the amounts of $3,365.40 and $5,776.50, respectively. The only issue for decision is whether payments made in each of those 2 taxable years by petitioner Ramon A. Shane to his former spouse are deductible pursuant to section 215, I.R.C. 1954.
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