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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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