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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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