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)Page: Previous 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 Next
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