two items, each of which is "substantial". See sec.
6013(e)(3). The first item is respondent's determination
that petitioners failed to report gross income of $31,748,
computed using the bank deposits method of computing
income. The second item is respondent's determination
that Mr. DiMichele "realized a long-term capital gain
of $34,000.00 from the sale of 506 and 510 Fitzwater."
To satisfy section 6013(e)(1)(C), petitioner must
prove that in signing each of the returns in issue she
did not know, and had no reason to know, that there was
a substantial understatement of tax attributable to the
grossly erroneous items of her husband. See Purcell v.
Commissioner, 86 T.C. 228, 236 (1986), affd. 826 F.2d 470
(6th Cir. 1987). This is a question of fact to be deter-
mined after considering all available facts and circum-
stances. E.g., Flynn v. Commissioner, 93 T.C. 355, 365
(1989).
Petitioner argues that in signing her joint returns
for 1985 and 1986 she did not know, and had no reason to
know, that there was a substantial understatement of tax
on either of the returns. She argues that she has limited
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