United States Tax Court July 30, 1946, Docket No. 8829 (Budd v. Commissioner)

lead-opinion

OPINION.

Kern, Judge-.

The narrow issue presented by this proceeding is whether the $2,400 disallowed as a deduction by respondent is a “periodic payment which the terms of the decree or written instrument fix, in terms of an amount of money or a portion of the payment, as a sum which is payable for the support of minor children” of petitioner within the meaning of section 22 (k) of