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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.
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