Barbara A. Vriner, A.K.A. Barbara A. Coyne - Page 4

          arrests all involved alcohol and not narcotics.  Petitioner had             
          never seen any narcotics in their home.                                     
               Mr. Vriner subsequently was arrested, but he did not discuss           
          his arrest with petitioner.  After reading the newspaper and                
          attending her husband's court appearances, petitioner learned               
          that Mr. Vriner and his brother had been trafficking in                     
          narcotics, and they stored the narcotics in a warehouse located             
          in Urbana, Illinois.  The deficiency in this case stems from the            
          proceeds of the Vriner brothers' drug activities.                           
               Spouses filing a joint return are jointly and severally                
          liable for the tax arising therefrom.  Sec. 6013(d)(3).  The                
          innocent spouse rule permits a spouse to avoid joint and several            
          liability in certain cases. Sec. 6013(e).  For petitioner to                
          qualify as an innocent spouse, it must be established:  (1) That            
          a joint return was filed for the year in issue; (2) that there              
          was a substantial understatement of tax attributable to grossly             
          erroneous items of Mr. Vriner; (3) that, in signing the return,             
          she did not know or have reason to know of the substantial                  
          understatement; and (4) that taking into account all the facts              
          and circumstances, it would be inequitable to hold her liable for           
          the deficiency.  Sec. 6013(e)(1)(A)-(D).  Petitioner has the                
          burden of proving each requirement of section 6013(e).  Rule                
          142(a); Russo v. Commissioner, 98 T.C. 28, 31-32 (1992).  A                 
          failure to meet any one of the requirements will preclude the               

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