- 2 -
The decision to be entered is not reviewable by any other court,
and this opinion should not be cited as authority.
The case arises from petitioner’s election to seek relief
from joint and several liability for Federal income tax for
petitioner’s 2001 taxable year under section 6015(f). Respondent
determined that petitioner is not entitled to relief.
The issue for decision is whether respondent’s determination
that petitioner is not entitled to relief under section 6015(f)
is an abuse of discretion.
Background
Some of the facts are stipulated. The stipulated facts and
the exhibits received into evidence are incorporated herein by
reference. At the time the petition in this case was filed,
petitioner resided in Grapevine, Texas.
During 2001, petitioner was married to Sherri D. Taylor
(intervenor). Petitioner, an accountant, has a college degree
and owned the S corporation by which he was employed, Archive
Litigation Services, Inc. (Archive). Intervenor has a high
school diploma and was employed as a business manager for which
she reported wages of $73,352.40.
Intervenor was also a part owner of three “passthrough”
entities, Armstrong Archives, LLC (Armstrong), Property Leasing
X, LLP (Property), and United Business Services. Intervenor
reported net income from Armstrong and Property for 2001 and
Page: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011