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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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