- 48 -
understatements of income tax. Petitioners underreported their
income by about $47,068 in 1987 and $87,711 in 1988. Petitioners
have cited no authority for their failure to report those items
of income. We sustain respondent's determinations that
petitioners are liable for the addition to tax under section 6661
for 1987 and 1988.
11. Whether Petitioner Qualifies as an Innocent Spouse
a. Background
We next decide whether petitioner wife qualifies as an
innocent spouse under section 6013(e).
Spouses who file joint tax returns generally are jointly and
severally liable for tax. Sec. 6013(d)(3). Petitioner argues
that she is not liable for the deficiencies and addition to tax
for substantial understatement of income tax because she is an
innocent spouse under section 6013(e). To qualify as an innocent
spouse, petitioner must prove that: (i) She filed a joint return
for the years in issue; (ii) there is a substantial
understatement of income tax attributable to grossly erroneous
items of the other spouse on the return; (iii) she did not know
or have reason to know of the substantial understatement when
she signed the return; and (iv) 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
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