Patricia A. Price v. Commissioner of Internal Revenue

O’SCANNLAIN, Circuit Judge:

This appeal turns on interpretation of the defense to joint federal income tax liability known as the “innocent spouse” provision of the Internal Revenue Code. The wife-taxpayer asserts that the tax court erred by applying an incorrect standard in determining that she was ineligible for relief under this provision. She claims that she was “innocent” within the meaning of the provision at the time she signed the return, and thus should be shielded from liability as to the tax deficiency arising from a deduction as to which her husband-taxpayer had superior knowledge.…