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were written during 1991; petitioner signed only five of those
checks totaling $135.
Federal Tax Return
On June 3, 1993, petitioner and Mr. Muhn filed a 1991 joint
Federal income tax return, reporting an adjusted gross income of
$25,880. Petitioner did not review the delinquent return even
though at the time the return was filed, Mr. Muhn was under
examination with regard to his 1991 tax liability and petitioner
was aware of the tax examination.
Notice of Deficiency
In the notice of deficiency, respondent determined a tax
deficiency of $14,733. For the most part, the deficiency was
attributable to $41,665 of unreported income (1) from Mr. Muhn's
work for the Ruidoso Valley Chamber of Commerce ($14,019), and (2)
the net income of PFA ($27,646).
Discussion
The sole issue for decision is whether petitioner qualifies
for innocent spouse relief for the 1991 deficiency and additions.
Spouses who file a joint income tax 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)(3). However, pursuant to
section 6013(e), a spouse (commonly referred to as an innocent
spouse) can be relieved of tax liability if that spouse proves: (1)
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