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OPINION
Petitioner bears the burden of proving that respondent's
determinations in the notice are erroneous. Rule 142(a); Welch
v. Helvering, 290 U.S. 111, 115 (1933). To satisfy that burden
with respect to the issues remaining in this case, petitioner
relies on her testimony and that of Mr. Morris, as well as on
various documents. We do not question the general credibility of
petitioner.21 However, as discussed below, we do have reserva-
tions about some of the matters to which Mr. Morris testified.
Innocent Spouse
Petitioner claims that she qualifies for innocent spouse
relief under section 6013(e) only with respect to the portion of
the deficiency (1) for 1987 that is attributable to the unre-
ported embezzlement income and the erroneous deductions claimed
for a business bad debt and the legal expenses incurred to
recover that debt and (2) for each of the years 1988 and 1989
that is attributable to the unreported embezzlement income.
Section 6013(e) provides in pertinent part:
(e) Spouse Relieved of Liability in Certain Cases.--
21 During her direct testimony, petitioner testified that she
did not write any checks on the Meadows bank accounts. On cross-
examination, respondent introduced a check written by petitioner
on the Meadows account at the Champaign National Bank. We be-
lieve petitioner's testimony that she did not remember writing
that check and do not question the reliability of her testimony
as a result of that, or any other, lapse of memory during her
testimony.
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