Don C. Reser and Rebecca Jo Reser - Page 3

                                          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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