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income was not so extraordinary as to lead a reasonably prudent
person in her position to be alerted to problems. As we have
said before, innocent spouse relief is designed to protect the
innocent, not the intentionally ignorant. Cohen v. Commissioner,
T.C. Memo. 1987-537; Dickey v. Commissioner, T.C. Memo. 1985-478.
We are not persuaded that Mrs. Barnhill did not have reason to
know that there were substantial understatements of tax on the
returns in issue.
Moreover, there is no evidence that it would be inequitable
to hold Mrs. Barnhill liable for the deficiencies in issue here.
This is not a case where the spouse seeking relief has been left
alone to satisfy the deficiencies. Cf. Pietromonaco v.
Commissioner, supra; Price v. Commissioner, supra. Petitioners
are still married and continue to share the benefits and burdens
of that relationship just as they shared the benefits of the tax
savings claimed on the joint returns for the years in issue.
They have pointed to no circumstances that make it unfair to hold
her to the liability determined with respect to those joint
returns. A party to a joint return is not relieved of liability
merely because the transactions reported on the return are all
attributable to the other spouse. We agree with respondent that
Mrs. Barnhill has failed to satisfy the requirements of either
section 6013(e)(1)(C) or (D).
To reflect the stipulation of settled issues and our
determination herein,
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