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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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