- 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 andPage: Previous 1 2 3 4 5 6 7 8 9 10 Next
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