Martin v. Comr., T.C. Sum. Op. 2013-31

(petitioner got divorced and decree required him to pay $1,000 monthly spousal support; three years later ex-wife fell on financial hard times and sought increased support; petitioner increased support by $1,300 and sought alimony deduction without any modification of divorce decree; ex-wife did provide letter explaining situation a year later; under I.R.C. Sec. 71(b)(1), payment must be received by or on behalf of spouse under divorce or separation instrument; court determined that letters did not demonstrate "meeting of minds" between former spouses to constitute written separation agreement; no deduction allowed and ex-wife did not report increased amount as income).