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PRICE v. C.I.R.

No. 88-7124.

887 F.2d 959 (1989)

Patricia A. PRICE, Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Ninth Circuit.

Decided October 18, 1989.

Attorney(s) appearing for the Case

Kevin G. Staker, Gregory R. Gose, Staker & Gose, Camarillo, Cal., for petitioner-appellant.

William S. Rose, Asst. U.S. Atty. Gen., Gary R. Allen, Robert S. Pomerance, Barbara I. Hodges, Attys., Tax Div., U.S. Dept. of Justice, Washington, D.C., for respondent-appellee.

Before REINHARDT and O'SCANNLAIN, Circuit Judges, and COYLE, District Judge.

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...

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