SILAK, Judge.
Michael and Linda Badell executed a Marriage Settlement Agreement (the Agreement) in November, 1988, in anticipation of the dissolution of their marriage. Earlier in their marriage, Michael had used his separate property to pay $44,000 of the couple's anticipated 1986 tax liability; this resulted in a large overpayment. A portion of the overpayment was applied to the couple's tax liability for 1987 and 1988, leaving a total overpayment of $11,258. In...
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