Memorandum Findings of Fact and Opinion
COHEN, Judge:
Respondent determined deficiencies of $38,376, $74,901, and $190,357 in petitioners' Federal income tax for 1981, 1982, and 1983, respectively. After concessions, the sole issue remaining for decision is whether monthly payments made by Albert L. East III (petitioner) to his former wife Jean Ann Smith East (Jean East) are deductible alimony payments under section 215.
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