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tax due on their joint Federal income tax returns. Sec. 6013(d).
In limited circumstances, however, a spouse may qualify as an
"innocent spouse" and be relieved of joint and several liability.
Sec. 6013(e). The spouse seeking relief under section 6013(e)
bears the burden of proof. Rule 142(a); Bokum v. Commissioner,
94 T.C. 126, 138 (1990), affd. 992 F.2d 1132 (11th Cir. 1993).
In order for Mrs. Streck to qualify for innocent spouse
status, she must prove that: (1) Petitioners filed a joint tax
return; (2) on that joint tax return, there was a substantial
understatement of tax attributable to grossly erroneous items of
the other spouse; (3) in signing the joint tax return, she did
not know, nor have reason to know of the substantial
understatement; and (4) taking into account all the facts and
circumstances, it is inequitable to hold her liable for any
deficiency attributable to the substantial understatement. Sec.
6013(e)(1)(A)-(D). Failure to meet any one of these requirements
will prevent Mrs. Streck from qualifying as an innocent spouse.
Bokum v. Commissioner, supra at 138. The parties agree that
petitioners filed joint tax returns for 1983, 1984, 1985, and
1986. Respondent also concedes that there are substantial
understatements on petitioners' tax returns for those years and
that the unreported income for the years 1983 through 1985
constitutes grossly erroneous items of Mr. Streck.14
14Mrs. Streck claims that for purposes of sec. 6013(e), the
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