her awareness of all the benefits accruing from these
activities as discussed above. Petitioner therefore must
have had direct knowledge of the drug activities when she
signed the joint income tax returns.
Partial Liability Predicated on Partial Knowledge
Petitioner asks the Court to hold petitioner liable
for only so much of the deficiency as she was aware of.
This argument is based on the court's holding in Ratana v.
Commissioner, 662 F.2d 220 (4th Cir. 1981). There, the
court found that a wife seeking "innocent spouse" relief
was liable for only that tax attributable to the unreported
income of which she had actual or constructive knowledge
but that she was entitled to "innocent spouse" relief as to
the rest of the unreported income. Id. at 225. See
Purificato, supra at 297. Given the evidence provided in
the record, however, we conclude that we do not have
information specific enough to make such a determination.
We, therefore, find Ratana inapposite. Since it is
factually distinguishable, we do not have occasion to
discuss the application of the methodology used in Ratana.
1978 1979 1980 1981 1982 1983 1984 1985 1986
Schedule C
General Sign Co.$3,925$18,809
Wages-- 1,200$28,700$4,000
General Sign Co.
Wages--Out of
the Past, Inc.
Mr. DiMichele $18,000$26,000$19,500$2,400
Petitioner 6,50023,400
Installment sale
of business
Capital 8,658 380 363 11,726
Oridinary 4,906 215 206 3,472
Capital Gain $6,175
Schedule E
Vacant property (171)
1533 Emily (1,243)(1,996)(1,846)
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