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the minds. Kronish v. Commissioner, 90 T.C. 684, 693 (1988). A
letter which does not show that there was a meeting of the minds
is not a written separation agreement under the statute. Grant
v. Commissioner, supra at 823; Estate of Hill v. Commissioner, 59
T.C. 846, 856-857 (1973). To be given effect under section
71(b)(2), a written separation agreement "at least requires more
than a written statement by one spouse offering to make support
payments, and the acceptance of those payments by the other
spouse." Nemeth v. Commissioner, T.C. Memo. 1982-646. A letter
may satisfy the requirements of section 71(b)(2) even in the
absence of the parties' signatures if it embodies the terms of a
prior oral agreement or understanding. See Jefferson v.
Commissioner, 13 T.C. 1092, 1097-1098 (1949); Osterbauer v.
Commissioner, T.C. Memo. 1982-266.
Petitioner cites Azenaro v. Commissioner, T.C. Memo. 1989-
224, in support of his position that the March 30, 1992, letter
constitutes a written separation agreement. However, that case
is distinguishable from the case at hand. In Azenaro v.
Commissioner, supra, we held that a letter from the attorney for
the taxpayer's husband, 1 year after the couple separated, which
offered a monthly payment and which was subsequently received and
signed by the recipient taxpayer, constituted a valid written
separation agreement. The letter, as acknowledged and accepted
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