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Thus, Linda has failed to establish that the deductions are
grossly erroneous. Accordingly, we conclude that Linda, pursuant
to section 6013(e), is not entitled to be relieved of tax
liability with respect to the disallowed deductions.
Respondent also determined that petitioners did not report
$22,715 of income from Ronnie's law practice. Omissions from
gross income are grossly erroneous. Sec. 6013(e)(2). The
understatement of tax attributable to the omitted income is
substantial because it exceeds $500. Sec. 6013(e)(3). In
addition, respondent has conceded that the omission is
attributable to items of Ronnie. Accordingly, with respect to
the omitted income, we conclude that Linda has established a
substantial understatement of tax attributable to grossly
erroneous items of Ronnie. We next determine whether Linda meets
the remaining requirements of section 6013(e).
II. Knowledge Requirement
Linda must establish that in signing the return, she did not
know, and had no reason to know, of the substantial
understatement of tax attributable to the omitted income from
Ronnie's law practice. Sec. 6013(e)(1)(C). More specifically,
she must establish that she did not know, or have reason to know,
about the income-producing transaction that Ronnie failed to
report. Park v. Commissioner, supra at 1294; Bokum v.
Commissioner, supra at 146. A spouse seeking relief has reason
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