-58-
Furthermore, petitioner's failure to provide his accountants
all of the necessary and relevant information is an indication
that he did not make an effort to assess the proper tax liability
for each of the years at issue.
On the basis of the record as a whole, we conclude that
petitioners have not carried their burden of proving that they
acted with reasonable cause and in good faith. We hold that
petitioners are liable for the accuracy-related penalty under
section 6662 for 1989, 1990, and 1991.
Issue 7. Whether Mrs. Jones Qualifies Under Section 6013(e) as
an Innocent Spouse
Mrs. Jones contends that she is not liable for the
understatement of tax because she qualifies as an innocent spouse
pursuant to section 6013(e).
Spouses who file a joint return generally are jointly and
severally liable for its accuracy and the tax due, including any
additional taxes, interest, or penalties determined on audit of
the return. Sec. 6013(d). However, section 6013(e) provides an
exception. A spouse (commonly referred to as an innocent spouse)
is relieved of tax liability if that spouse proves: (A) A joint
return was filed for the years in issue; (B) the return contained
a substantial understatement (defined in section 6013(e)(3) as
any understatement over $500) of tax attributable to grossly
erroneous items of the other spouse; (C) in signing the return,
the spouse seeking relief did not know, and had no reason to
know, of the substantial understatement; and (D) it would be
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