-9- 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 anPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 Next
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