- 10 - 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,Page: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
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