Della H. Knorr and Duane J. Knorr - Page 2

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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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