Kirk A. Keegan, Jr. - Page 4

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                  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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