3
(6) Is petitioner wife entitled to the innocent spouse
treatment provided for by section 6013(e)? We hold that she is
not.
FINDINGS OF FACT
Some of the facts are stipulated and are so found. The
stipulation of facts and exhibits attached thereto are
incorporated herein by this reference. Petitioners resided in
San Antonio, Texas, at the time the petition was filed.
Petitioner husband (hereinafter petitioner) received an A.B. in
economics from Stanford University, an M.B.A. from the University
of Texas, and a J.D. from the University of Houston Law School.
Petitioner wife received her undergraduate degree in history from
Stanford and her J.D. from the University of Texas Law School in
December 1975. Petitioners were married on March 30, 1974. They
had two children prior to their divorce on August 5, 1991.
In 1984, petitioner filed articles of incorporation for Don
C. Reser, P.C. (hereinafter DRPC), which elected subchapter S
status in that year. Petitioner was the sole shareholder of
DRPC, which was initially capitalized with $6,000. During the
years in issue, DRPC's main business purpose was to broker a real
estate transaction.
During 1985, petitioner and DRPC together obtained a line of
credit from North Frost Bank of San Antonio, Texas (later known
as Frost National Bank and hereinafter referred to as Frost
Bank), in the name of petitioner and DRPC. Petitioner and DRPC
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