Sandrus L. Collier - Page 10

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                         The Wife hereby assumes and agrees to pay the                
               joint debt to Apple Federal Credit Union in the approx-                
               imate amount of $10,000.00 incurred by the parties                     
               prior to the execution of this Agreement, and shall                    
               indemnify and hold the Husband harmless thereon.                       
               In a document entitled “JUDGMENT OF ABSOLUTE DIVORCE”                  
          (judgment of divorce), the Circuit Court for Prince George’s                
          County, Maryland, ordered, inter alia, “that all the terms and              
          provisions of the Agreement of the parties dated the 16th day of            
          March, 1996 * * * be * * * incorporated, but not merged, into the           
          judgment by reference”.  On January 2, 1997, that court entered             
          that judgment of divorce.                                                   
               On April 8, 2000, Ms. Collier sent respondent the then                 
          current version of Form 8857, Request for Innocent Spouse Relief            
          (And Separation of Liability and Equitable Relief) (Form 8857),             
          which respondent had instructed her to complete.7  In that form,            
          Ms. Collier requested relief under section 6015(b), (c), and (f).           
          Ms. Collier attached the following statement to Form 8857:                  
               Dear IRS: Request for Innocent Spouse Relief Division,                 
               I am requesting Innocent Spouse Relief for the FYE                     
               1988.  I do not have a refund this year as in previous                 
               years.  My employer has changed the month of our FYE                   
               from July to December.  With doing this I managed to                   
               break even this year.  I am asking for relief from                     
               previous years if possible.  I know my ex-husband has                  
               applied for an offer in compromise.  I do not know what                
               the status of our taxes are as he seems to be very                     
               secretive about this.  I thought he was in good stand-                 

               7On Oct. 2, 1998, Ms. Collier sent respondent a prior ver-             
          sion of Form 8857, in which she requested relief under sec. 6015.           

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