- 5 - 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 thatPage: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
Last modified: May 25, 2011