MEMORANDUM OPINION
LARO, Judge:
The parties submitted this case to the Court without trial. See Rule 122. Petitioners petitioned the Court to redetermine respondent's determination of a $14,832 deficiency in their 1993 Federal income tax. We must decide whether they may deduct as alimony a $47,900 payment that Thomas Maloney (petitioner) made to his former wife. We hold they may not. Section references are to the Internal Revenue Code as applicable to the...
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