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          sec. 6013(e)(1)(A); (2) there was a substantial understatement of           
          tax attributable to grossly erroneous items of one spouse; sec.             
          6013(e)(1)(B); (3) at the time of signing the return, the other             
          spouse did not know and had no reason to know that there was such           
          an understatement; sec. 6013(e)(1)(C); (4) taking into account              
          all the facts and circumstances, it would be inequitable to hold            
          the other spouse liable for the deficiency in tax for such                  
          taxable year attributable to the understatement.  Sec.                      
          6013(e)(1)(D).                                                              
               For purposes of section 6013(e), an understatement of tax is           
          substantial if it exceeds $500.  Sec. 6013(e)(3).  With respect             
          to grossly erroneous deductions, the understatement must exceed a           
          specified percentage of the putative innocent spouse’s gross                
          income for the “preadjustment year”, which is the taxable year              
          immediately preceding the year in which the statutory notice of             
          deficiency was issued.  Sec. 6013(e)(4).                                    
               The taxpayer has the burden of proving each element by a               
          preponderance of the evidence.  Rule 142(a); Stevens v.                     
          Commissioner, 872 F.2d 1499, 1504 (11th Cir. 1989), affg. T.C.              
          Memo. 1988-63; Purcell v. Commissioner, 826 F.2d 470, 473 (6th              
          Cir. 1987), affg. 86 T.C. 228 (1986); Sonnenborn v. Commissioner,           
          57 T.C. 373, 382 (1971).  Failure to carry that burden on any one           
          of the elements will prevent a taxpayer from qualifying for                 
          innocent spouse relief.  Purificato v. Commissioner, 9 F.3d 290,            
          293 (3d Cir. 1993), affg. T.C. Memo. 1992-580; Stevens v.                   
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