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ties other than those contained herein; and that this
Agreement shall not be modified except in writing,
signed by each of the parties hereto.
* * * * * * *
16. Deborah Messina has fully discussed the terms
of this Agreement with her undersigned attorney and has
fully reviewed them with her attorney. Based upon that
review and discussion with her counsel, Deborah Messina
hereby acknowledges that she fully and completely
understands and agrees to the terms of this Agreement.
In anticipation of petitioner’s signing the agreement,
William Ober (Mr. Ober), petitioner’s attorney, had discussions
with a representative of the Office of the Attorney General of
the State of Maryland (Maryland Attorney General) concerning Mr.
Ober’s proposal to allow petitioner to claim a higher number of
exemptions in Form W-4, Employee’s Withholding Allowance Certifi-
cate (Form W-4), in an effort to reduce significantly the amount
of Federal and State tax that the State of Maryland was to
withhold from the $170,000 that the State of Maryland agreed to
pay to petitioner under the agreement. On April 26, 1994, that
representative sent a letter to Mr. Ober (Maryland Attorney
General’s April 26, 1994 letter) with respect to Mr. Ober’s
proposal. That letter stated in pertinent part:
This is to confirm our conversation of 4/26/94
regarding your proposal to allow Mrs. Messina to claim
a higher number of exemptions on her W-4 Form in order
to substantially reduce the projected withholding of
$60,136.
As we discussed, I spoke to Ellen Coffin of the
[Maryland] Comptroller’s Office who stated that a State
employee may claim more exemptions than they actually
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