Beverly D. Goings - Page 15

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               Pursuant to section 6013(e)(1), an "innocent spouse" is                
          relieved of liability if he or she proves:  (1) A joint return              
          has been made for a taxable year; (2) on such return there is a             
          substantial understatement of tax attributable to grossly                   
          erroneous items of the other spouse; (3) he or she did not know,            
          and had no reason to know, of such understatement when he or she            
          signed the return; and (4) after consideration of all the facts             
          and circumstances, it would be inequitable to hold him or her               
          liable for the deficiency in income tax attributable to such                
          understatement.  See Park v. Commissioner, supra at 1292.                   
          Petitioner bears the burden of establishing that each of the four           
          requirements of section 6013(e) has been satisfied.  Purcell v.             
          Commissioner, 826 F.2d 470, 473 (6th Cir. 1987), affg. 86 T.C.              
          228 (1986); Sonnenborn v. Commissioner, supra at 381-383.                   
          Moreover, the requirements of section 6013(e) are conjunctive; a            
          failure to meet any one requirement prevents a spouse from                  
          qualifying for relief.  Park v. Commissioner, supra at 1292;                
          Purcell v. Commissioner, supra; Bokum v. Commissioner, 94 T.C.              
          126, 138 (1990), affd. 992 F.2d 1132 (11th Cir. 1993).                      
               The parties agree that petitioner and Mr. Goings filed a               
          joint return for each taxable year at issue.  The parties also              
          agree that there is a substantial understatement of tax                     
          attributable to grossly erroneous items of Mr. Goings for each              
          taxable year at issue.  Respondent contends, however, that                  
          petitioner knew or had reason to know of such substantial                   




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