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Discussion
We must decide whether petitioner may deduct as alimony
under section 215 payments to, or on behalf of, Mrs. Keegan in
the total amount of $17,934 that were made prior to the entry of
the Stipulation and Order to Show Cause on May 6, 1992.
Petitioner has conceded that additional payments totaling $16,372
made prior to that date are not deductible.
As a preliminary evidentiary matter, we must decide whether
to reopen the record in this case to permit petitioner to include
two letters which are attached to petitioner's Memorandum of
Authorities filed in lieu of a posttrial brief by direction of
the Court. Pursuant to the Court's Order dated June 19, 1997,
directing respondent to file, on or before July 9, 1997, any
objection to the record's being reopened to receive the letters
in evidence, respondent has filed a Notice of Objection to the
record's being reopened for this purpose on the grounds of
hearsay and undue prejudice. Reopening the record for the
submission of additional proof lies within the discretion of the
Court. Zenith Radio Corp. v. Hazeltine Research, Inc., 401 U.S.
321, 331 (1971). Petitioner is not represented by counsel in
this case, and in the interest of justice and for completeness we
deem it appropriate to receive the two letters in evidence.
Respondent is not prejudiced, however, because, as discussed
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