Kirk A. Keegan, Jr. - Page 10

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            Commissioner, supra, we stated that the letter from the taxpayer                          
            to his wife "embodied the terms of a prior oral agreement or                              
            understanding * * * with reference to periodic payments to be                             
            made for the wife's support and maintenance, and that the letter                          
            confirmed that oral agreement or understanding."  Id. at 1097.                            
            (Emphasis added.)  The letter relied upon by the taxpayer                                 
            therein, although it did not bear his wife's signature and no                             
            other writing was executed on her behalf, nonetheless clearly                             
            recited the parties' prior oral agreement that he would pay his                           
            wife a specified sum of support and thus sufficed for purposes of                         
            the statutory predecessor of section 215.                                                 
                  In contrast, in the instant case, the March 30, 1992, letter                        
            does not memorialize any prior agreement between petitioner and                           
            Mrs. Keegan.  To the extent that the June 12, 1996, letter from                           
            Briggs (purporting to summarize events that occurred 4 years                              
            earlier) implies that the March 30, 1992, letter embodies the                             
            terms of a previous oral understanding, we think that Briggs                              
            mischaracterizes the contents of the earlier letter.  In any                              
            event, the March 30, 1992, letter fails to confirm such an oral                           
            agreement.  See id. at 1097.                                                              
                  Petitioner himself acknowledges that the March 30, 1992,                            
            letter was a mere proposal, albeit one that was accepted by his                           
            wife "on or prior to April 1, 1992."  Yet, as mentioned above,                            

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