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FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulation of facts is incorporated herein by this
reference.
Petitioners
Petitioners were married and resided in Fernandina Beach,
Florida, at the time their petition was filed. Petitioners filed
joint Federal income tax returns for 1989, 1990, and 1991.
Petitioners began divorce proceedings in 1992. On October
10, 1994, petitioners signed a mediated settlement agreement with
respect to their divorce. In that agreement, Mr. Garrett agreed
to indemnify Mrs. Garrett for all Federal income taxes,
penalties, and interest accruing during their marriage through
the calendar year 1992. In addition, the indemnification
agreement provides Mrs. Garrett with a lien interest against Mr.
Garrett's collection of automobiles until such time as the
Federal income tax liability has been fully discharged and
released. Although the marriage was dissolved in 1995, certain
property issues are on appeal.
Mr. Garrett's Corporations
Mr. Garrett was the sole owner of Floyd Garrett, Inc. (FGI),
a trucking company located in Fernandina Beach, Florida. FGI was
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