- 26 - Commissioner, supra at 1504; Purcell v. Commissioner, supra at 473. The parties agree that a joint return was filed. The record also compels the conclusion that the understatement of $55,263 attributable to the items in question was substantial, sec. 6013(e)(3), and we so find. Respondent has contested each of the remaining issues, including whether the deficiency exceeds the specified percentage of petitioner’s adjusted gross income for 1983, her preadjustment year. Sec. 6013(e)(4)(C). Section 6013(e)(4)(A) requires that the substantial understatement exceed 10 percent of the claimant spouse’s adjusted gross income (AGI) for the preadjustment year if the AGI is $20,000 or less. We find that petitioner’s adjusted gross income for 1983 could not have exceeded $6,835 even if additional items of income described in the record, which may well have been reported in other taxable years, are added to petitioner’s reported 1983 adjusted gross income. The understatement of $55,263 exceeds 10 percent of petitioner’s 1983 adjusted gross income. We consider each of the remaining contested elements. 1. “Grossly Erroneous Items of One Spouse” a. Attributable to Other Spouse Respondent does not argue that the disallowed Stonehurst deductions claimed on the 1979 return were not attributable to Mr. Heitzman. The record shows that petitioner had no ownershipPage: Previous 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 Next
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