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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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Last modified: May 25, 2011