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dispute. Further, the parties have stipulated that the $43,158
of income that was omitted from the 1982 Federal income tax
return is a grossly erroneous item. Therefore, the issues for
decision are: (1) Whether the understatement of income for the
taxable year 1981 from the Supertaps loss deduction is a "grossly
erroneous item," as defined by section 6013(e)(2)(B), attribut-
able solely to Thomas Dillon, and whether the omission of income
from the 1982 Federal income tax return is attributable solely to
Thomas Dillon; (2) whether petitioner, in signing the 1981 and
1982 Federal income tax returns, did not know or have reason to
know of the substantial understatement of tax in 1981 which
resulted from the Supertaps deduction or the substantial under-
statement of tax in 1982 which resulted from the failure to
report income from the Murphy Favre account; (3) whether it would
be inequitable to hold petitioner liable for the deficiencies in
income tax for 1981 and 1982 attributable to the substantial
understatements.
The 1981 Disallowed Loss Deduction for Supertaps
Petitioner contends that she is entitled to innocent spouse
relief with respect to the 1981 deficiency arising from the
Supertaps investment. In order to prevail, petitioner must
prove: (1) That the substantial understatement is a grossly
erroneous item; (2) that the substantial understatement is
attributable solely to Thomas Dillon; (3) that petitioner did not
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