Vernon Stacy Taylor - Page 3

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          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                






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