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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