United States Tax Court February 29, 1968, Docket Nos. 2809-63, 5258-65 (Reisman v. Commissioner)

lead-opinion

OPINION

The principal issue for our consideration is whether periodic payments made ¡by George to Fredricka from 1958 through 1962 under a New York annulment decree qualify as alimony under section 71(a) (1)3 so as to be includable in Fredricka’s gross income and deductible 'by George under section 215 ( a).