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burden.” Petitioner has taken no legal action against Mr. Barber
to enforce the divorce decree making him responsible for their
unpaid taxes.
After the divorce, petitioner earned wages on which Federal
income taxes were withheld. She resumed filing separate returns
in 1995. Her 1995, 1996, and 1997 returns had overpayments of
$130, $2,155, and $1,730, respectively, which respondent applied
to the joint debt for 1987. The application of these
overpayments occurred prior to July 22, 1998. Her 1998 return,
filed in October 1999, showed an overpayment of $1,675, $920.05
of which was also applied to the 1987 debt during the week of
November 21-27, 1999. The remainder of the 1998 overpayment was
applied to her 1988 tax debt. The applied overpayments, totaling
$4,935.05, along with petitioner’s 1987 withholding, another
payment by levy, and an additional overpayment from the 1994
joint return, satisfied the amount due from 1987, including all
taxes, interest, and penalties assessed for that year.
In 1999, petitioner engaged the assistance of Leonard E.
Goldammer, an enrolled agent authorized to practice before the
IRS. In May 2000, on petitioner’s behalf, Mr. Goldammer filed
with the IRS a Form 8857, Request for Innocent Spouse Relief, for
the years 1987 through 1993.2 As part of her request for relief,
2 Mr. Goldammer simultaneously filed Forms 843, Claim for
(continued...)
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