Carl Dimichele and Eileen Dimichele - Page 41

             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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