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relaxation of the rule of liability depends upon compliance with
the conditions of section 6013(e). Sonnenborn v. Commissioner,
57 T.C. 373, 380-381 (1971). Because of its remedial purpose,
however, the innocent spouse rule must not be given an unduly
narrow or restrictive reading. Sanders v. United States, 509
F.2d 162, 167 (5th Cir. 1975). The question whether a taxpayer
has established that he or she is entitled to relief as an
innocent spouse is one of fact. Park v. Commissioner, supra at
1291.
Section 6013(e)(1) provides in pertinent part that if:
(A) a joint return has been made under this
section for a taxable year,
(B) on such return there is a substantial
understatement of tax attributable to grossly erroneous
items of one spouse,
(C) the other spouse establishes that in
signing the return he or she did not know, and had no
reason to know, that there was such substantial
understatement, and
(D) taking into account all the facts and
circumstances, it is inequitable to hold the other
spouse liable for the deficiency in tax for such
taxable year attributable to such substantial
understatement,
then the other spouse shall be relieved of liability for tax
(including interest, penalties, and other amounts) for such
taxable year to the extent such liability is attributable to
such substantial understatement.
A taxpayer must prove that each requirement of section
6013(e) is met, and failure to prove any one of the requirements
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