Carl Dimichele and Eileen Dimichele - Page 17

             of the above requirements is satisfied.  Rule 142(a).  All               
             Rule references are to the Tax Court Rules of Practice and               
             Procedure.  Failure to prove any one of the above require-               
             ments precludes the taxpayer from qualifying as an                       
             "innocent spouse".  Bokum v. Commissioner, 94 T.C. 126,                  
             138 (1990), affd. 992 F.2d 1132 (11th Cir. 1993).                        
                  Respondent concedes that petitioner meets the first                 
             two requirements of the test with respect to both of the                 
             tax returns in issue.  Therefore, petitioner must prove                  
             that she meets the remaining two requirements; i.e.,                     
             that she had no knowledge nor reason to know about the                   
             substantial understatements, sec. 6013(e)(1)(C), and,                    
             taking into account all facts and circumstances, that it                 
             would be inequitable to hold her liable for the deficiency               
             in tax attributable to the substantial understatement for                
             the year, sec. 6013(e)(1)(D).                                            
                 For the year 1985, the substantial understatement of                
             tax is attributable entirely to respondent's determination               
             that petitioners failed to report the income and expenses                
             from Mr. DiMichele's activity as a drug dealer.  For the                 
             year 1986, the understatement of tax is attributable to                  

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