Rebecca C. Ratana v. Commissioner of Internal Revenue

SPROUSE, Circuit Judge:

This is an appeal by the Commissioner of Internal Revenue from a Tax Court ruling that Rebecca C. Ratana, the taxpayer, was not liable for taxes due on joint returns she and her husband filed.

The sole issue is whether the taxpayer is an “innocent spouse,” as defined in section 6013(e) of the Internal Revenue Code of 1954, and therefore not jointly liable for taxes on the unreported income earned in 1974 and 1975 by her husband. The taxpayer’s husband, a citizen of Thailand and a United States resident, was involved in a lucrative narcotics trade in 1974 and 1975. The…