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there is a substantial understatement of income tax attributable
to grossly erroneous items of the other spouse on the return; (c)
she did not know or have reason to know of the substantial
understatement when she signed the return; and (d) it would be
inequitable to hold her liable for the deficiency attributable to
the substantial understatement. Sec. 6013(e)(1). Failure to
meet any of these requirements precludes a taxpayer from
qualifying as an innocent spouse. Sec. 6013(e)(1); Purcell v.
Commissioner, 826 F.2d 470, 473 (6th Cir. 1987), affg. 86 T.C.
228 (1986). Courts should construe the innocent spouse exception
in view of the congressional purpose of protecting innocent
taxpayers from injustice. Sanders v. United States, 509
F.2d 162, 166-167 (5th Cir. 1975).
Respondent concedes that Ruth Levitt meets the requirements
to qualify as an innocent spouse under section 6013(e) except
that she knew or had no reason to know of the understatements
when she signed the returns and that it is inequitable to hold
her liable. We need not decide whether Ruth Levitt knew or had
reason to know of the understatements because we conclude that it
is not inequitable to hold her liable.
2. Whether It Is Inequitable to Hold Ruth Levitt Liable
A taxpayer who claims innocent spouse relief must prove
that, taking into account all the facts and circumstances, it
is inequitable to hold her or him liable for the deficiency.
Sec. 6013(e)(1)(D). Normal support is not a significant
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