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United States, 509 F.2d 162, 167 (5th Cir. 1975). The question
of whether a taxpayer has established that he or she is entitled
to relief as an "innocent spouse" is one of fact. Park v.
Commissioner, supra at 1291.
Pursuant to section 6013(e)(1), an "innocent spouse" is
relieved of liability if he or she proves that: (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 Purcell v. Commissioner, 86 T.C. 228, 235
(1986), affd. 826 F.2d 470 (6th Cir. 1987). 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 at 473; 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. Peterson filed a
joint return for each of the taxable years at issue. The parties
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