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for 1999. In his request for relief, petitioner said that he had
not seen intervenor’s Forms W-2 for 1999.
D. Petitioner’s and Intervenor’s Divorce Decree
Petitioner and intervenor were divorced on October 19, 2001.
The divorce decree orders:
IT IS ORDERED AND DECREED that the Petitioner
[Tamera Everett] shall pay and maintain the following
debts and obligations and shall indemnify and hold
Respondent [John Hollis] harmless and Respondent’s
property harmless from any failure to so discharge such
debts and obligations:
* * * * * * *
3. Any and all income tax due and owing by
Petitioner for the years 1999 through 2001, and any and
all income tax due and owing by the Petitioner as a
result of Petitioner under reporting her earning for
the year 1999. [Emphasis added.]
Intervenor’s divorce attorney wrote by hand everything underlined
in paragraph 3 in the presence of petitioner’s divorce attorney
and the judge presiding over the divorce.
The divorce decree also orders:
IT IS ORDERED AND DECREED that Respondent [John
Hollis] shall pay the following debts and obligations
and shall indemnify and hold Petitioner [Tamera
Everett] harmless and Petitioner’s property harmless
from any failure to so discharge such debts and
obligations:
* * * * * * *
3. Any and all income tax due and owing by
Respondent for the years 1999 through 2001.
On August 30, 2002, respondent issued a notice of
determination to petitioner denying relief under section 6015.
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