Cathy Miller Hardy v. Commissioner of Internal Revenue

THOMAS, Circuit Judge:

Cathy Hardy appeals a decision of the United States Tax Court, which affirmed the Internal Revenue Service’s (“IRS”) assessment of tax deficiency against her. On appeal, Hardy challenges the Tax Court’s allocation and application of the burden of proof as well as the Tax Court’s application of the so-called innocent spouse provisions of the Internal Revenue Code. We affirm.

I

In 1981, Cathy Miller married Ray Hardy, and they have resided in Nevada, a community property state, for the duration of their marriage. Cathy and Ray Hardy both had been previously married to other…