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respondent increased the deficiency to $19,269, and the additions
to tax pursuant to sections 6651(a)(1), 6653(a), and 6661 to
$4,212, $1,135, and $4,817, respectively.
Respondent and Sherburne M. Edmondson, Jr. (Mr. Edmondson),
entered into a Stipulation of Settled Issues (the settlement
stipulation) resolving all items in dispute except whether Diane L.
Edmondson (Ms. Edmondson), Mr. Edmondson's ex-wife, qualifies for
tax relief as an innocent spouse pursuant to section 6013(e). Ms.
Edmondson did not contest any of the compromised items, which would
have resulted in a deficiency in tax, including additions to tax,
being assessed jointly against her and Mr. Edmondson (but for
innocent spouse relief), but she refused to sign the settlement
stipulation because she felt "uncomfortable" doing so. In response
to the Court's inquiry, respondent's counsel agreed that should the
Court deny innocent spouse relief to Ms. Edmondson, respondent
would seek against her only the amount of taxes and additions to
tax computed under the settlement stipulation signed by Mr.
Edmondson and respondent.
In general, respondent's determinations are presumed correct.
Thus, except for a matter pleaded in respondent's amended answer
(discussed below), Ms. Edmondson bears the burden of proving
respondent's determinations erroneous. Rule 142(a); Welch v.
Helvering, 290 U.S. 111, 115 (1933). Since Ms. Edmondson failed to
introduce any evidence with regard to any item in dispute,
respondent's determinations with respect to those items where Ms.
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