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 DRPCPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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