Bruno and Francesca Tabbi - Page 48

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          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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