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amount of all payments from April 1, 1992, to May 6, 1992
($17,934), since, he argues, a written separation agreement
existed on April 1, 1992, within the meaning of section
71(b)(2)(B), in the form of the March 30, 1992, letter.
Respondent contends, on the other hand, that there was no written
agreement prior to the entry of the Stipulation and Order to Show
Cause. On that basis, respondent maintains that no alimony
deduction for the period prior to May 6, 1992, is allowable.
We have no doubt that the payments at issue were intended to
be in the nature of alimony; nevertheless, for reasons which
follow, we agree with respondent that the facts of this case show
that there was no written separation agreement within the ambit
of section 71(b)(2)(B) prior to May 6, 1992.
The term "written separation agreement" is not defined by
the Code, the legislative history, or applicable regulations.
Bogard v. Commissioner, 59 T.C. 97, 100 (1972); Ewell v.
Commissioner, T.C. Memo. 1996-253. However, we have stated
previously that a written separation agreement is a clear,
written statement of the terms of support for separated parties.
Bogard v. Commissioner, supra at 101. It must be a writing that
constitutes an agreement. Grant v. Commissioner, 84 T.C. 809,
823 (1985), affd. without published opinion 800 F.2d 260 (4th
Cir. 1986). An agreement requires mutual assent or a meeting of
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