Carl Dimichele and Eileen Dimichele - Page 2

                Additions to Tax                                                                           
                Sec.          Sec.          Sec.        Sec.      Sec.                                     
                Year  Deficiency  6653(a)(1)(A)  6653(a)(1)(B)  6653(b)(1)  6653(b)(2)   6661              
                1985  $265,182     --              --       $132,591              1      $66,296           
                1986    22,927     $1,146               1           --          --       5,732             
                1  Fifty percent of interest due on the deficiency.                                        

                Unless stated otherwise, all section references are to the                                 
                Internal Revenue Code as in effect during the years in                                     
                      Prior to trial, petitioner Carl DiMichele conceded                                   
                liability for the above tax deficiencies and additions to                                  
                tax, determined by respondent in two notices of deficiency                                 
                issued to petitioners.  At trial, respondent's attorney                                    
                conceded that no part of the underpayment for 1985 was due                                 
                to the fraud of petitioner Eileen DiMichele.  Following                                    
                those concessions, the only issue for decision is whether                                  
                petitioner Eileen DiMichele qualifies as a so-called                                       
                innocent spouse under section 6013(e) and should be                                        
                relieved of liability for the subject tax deficiencies                                     
                and the additions to tax for 1986.  Therefore, all                                         
                further references to "petitioner" are references to                                       
                Mrs. DiMichele.                                                                            

                                           FINDINGS OF FACT                                                
                      The parties have stipulated some of the facts in these                               
                consolidated cases.  The Stipulation of Facts filed by the                                 

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