United States Tax Court February 10, 1949, Docket No. 13466 (Orsatti v. Commissioner)

lead-opinion

OPINION.

Arundell, Judge’.

The principal issue between the parties is whether, under the facts in the instant case, payments made by decedent to his wife pursuant to the property settlement agreement incident to their divorce were “periodic” or “installment” payments within the meaning of section 22 (k) of the Internal Revenue Code.