OPINION
SUTTON, Circuit Judge.
This appeal arises from income tax deficiencies and fraud-penalty assessments levied by the IRS and upheld by the Tax Court. Because the Tax Court did not clearly err (1) in finding that Homer Richardson fraudulently created sham trusts and underreported the couple's income and (2) in finding that Gloria Richardson failed to show that she was entitled to innocent-spouse relief, we affirm.
I.
Homer and Gloria...
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