- 2 - decision is whether respondent abused respondent’s discretion in denying petitioner’s request for relief from joint and several liability under section 6015(f) for those years. Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the years in issue. All amounts have been rounded to the nearest dollar. FINDINGS OF FACT Some of the facts have been stipulated, and the stipulated facts are incorporated in our findings by this reference. At the time that the petition in this case was filed, petitioner resided in Naples, Florida. Background Petitioner married Duane J. Knorr (intervenor) on August 23, 1980. They had three children during the course of their marriage. Throughout their marriage, petitioner was a homemaker, and intervenor owned and operated a commercial painting and wall- covering installation business. Intervenor organized his business as a Florida corporation in February 1987 under the name Universal Painters & Vinyl Hangers, Inc. (Universal Painters). Universal Painters was operated as an S corporation during the years in issue. Petitioner did not participate in the business activities of Universal Painters, but she was aware of the significant growth in the business’s size and profitability during the course of her marriage to intervenor.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011