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that time.
On May 25, 1992, respondent assessed $12,778 with respect to
the taxable year 1991 of Ms. Collier and Mr. Collier. Respondent
applied $4,628 of tax withheld against that assessment, which
left $8,150 unpaid. Ms. Collier and Mr. Collier did not enter
into an installment agreement or other arrangement to pay the
unpaid assessment for 1991.
On March 16, 1996, Ms. Collier and Mr. Collier signed a
document entitled “PROPERTY SETTLEMENT AND SEPARATION AGREEMENT”
(separation agreement). That agreement provided in pertinent
part:
4. WAIVER OF SPOUSAL SUPPORT
The parties hereby waive and release any
rights that they may have for the support and mainte-
nance, spousal support, or alimony of themselves, and
agree that they will at no time hereafter seek or ask,
in any manner, any monies of any nature from one an-
other except as set forth in this Agreement; and fur-
ther, that if proceedings in divorce are taken by
either of the parties, they will not in such proceed-
ings make any such demand.
* * * * * * *
16. DEBTS
Except as otherwise provided herein, each
party shall be solely responsible for any and all debts
solely in his or her name, and shall indemnify and hold
the other party harmless thereon.
The Husband hereby assumes and agrees to pay
the joint debt to the IRS in the approximate amount of
$22,000.00 incurred by the parties prior to the execu-
tion of this Agreement, and shall indemnify and hold
the Wife harmless thereon.
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