Sherburne M. Edmondson, Jr. and Diane L. Edmondson - Page 9

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          spouse relief.  Bokum v. Commissioner, 94 T.C. 126, 138-139 (1990),         
          affd. 992 F.2d 1132 (11th Cir. 1993).                                       
               In the case before us, respondent concedes that the Edmondsons         
          filed a 1988 joint income tax return and that a substantial                 
          understatement of tax exists.  As a result, the controversy herein          
          focuses  on  the  aforementioned  second,  third,  and  fourth              
          requirements, namely:  Whether the substantial understatement was           
          attributable to Mr. Edmondson's grossly erroneous items; whether            
          petitioner did not know, and had no reason to know, of the                  
          substantial understatement; and whether it would be inequitable to          
          hold petitioner liable for the income tax deficiency attributable           
          to such substantial understatement.                                         
               A.  Grossly Erroneous Items of the Other Spouse                        
               The phrase "grossly erroneous items" statutorily is defined to         
          mean with respect to any spouse (a) any item of gross income                
          attributable to that spouse which is omitted from gross income, and         
          (b) any claim of a deduction, credit, or basis by that spouse in an         

















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