Memorandum Opinion
MURDOCK, Judge: The Commissioner determined deficiencies in income tax as follows:
| Docket No. | Year | Deficiency |
| 49981 | 1943 | $3,844.61 |
| 1944 | 3,705.70 | |
| 1945 | 3,191.61 | |
| 49982 | 1947 | 2,590.89 |
| 49983 | 1949 | 2,481.82 |
| 1950 | 2,559.18 | |
| 1951 | 2,914.75 |
The petitioner filed her returns for the taxable years with the collector of internal revenue for the third district of New York.
The petitioner and Robert Lehman were married in 1929 and divorced in 1934. They had no children. The petitioner was the sole support of her mother. Ruch and Robert entered into a property settlement and separation agreement on March 10, 1934. It provided that Robert would pay Ruth $20,000 annually as long as she lived and remained unmarried and would pay Ruth's mother $5,000 annually for her life "for and in behalf of" Ruth. It was decided in the case of
Decisions will be entered under Rule 50.
