Kirk A. Keegan, Jr. - Page 5

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            infra, petitioner has not established that he may deduct under                            
            section 215 or any other section the $17,934 of payments                                  
            remaining in dispute.                                                                     
                  One of the letters, dated March 30, 1992 (the March 30,                             
            1992, letter), is from Steven E. Briggs (Briggs), petitioner's                            
            attorney in his domestic relations matter, to Mrs. Keegan's                               
            attorney.  It states in pertinent part that                                               

                  In an effort to resolve this pending Order to Show Cause,                           
                  Dr. Keegan would propose to pay Mrs. Keegan, as and for                             
                  spousal support the sum of $9,000 per month.  * * *  If this                        
                  arrangement is acceptable to your client let me know and I                          
                  will be happy to write up a stipulation, which would then                           
                  enable us to take the Order to Show Cause off calendar.                             
                  [Emphasis added.]                                                                   

                  The other letter, dated June 12, 1996 (the June 12, 1996                            
            letter), is from Briggs to petitioner.  It states in relevant                             
            part that the March 30, 1992, letter                                                      

                  set forth in writing that we would continue to make the                             
                  support payments as previously agreed, which you made.                              
                  * * *  All of the payments made between February and                                
                  May of 1992, were agreed upon by the parties and were                               
                  the subject of understandings in connection with which                              
                  the Order to Show Cause hearings were continued * * *.                              
                  As has often been stated, deductions are a matter of                                
            legislative grace, and taxpayers bear the burden of proving that                          

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