§6004

cs. 13172(a), 13222(b), 107 Stat. at 455, 479 (1993); Pub. L. No. 104-188, secs. 1206(a), 1316(b), 110 Stat. at 1776, 1786 (1996); Pub. L. No. 105-34, secs. 224(a), 508(d), 602(a), 973(a), 111 Stat. at 818, 860, 862, 898 (1997); Pub. L. No. 105-206, sec. 6004(e), 112 Stat. at 795 (1998); Pub. L. No. 105-277, sec. 1004(a)(1), 112 Stat. at 2681-888 (1998); Pub. L. No. 106-170, secs. 532(c)(1)(A) and (B), 537(a), 113 Stat. at 1930, 1936 (1999); Pub. L. No. 106-554, secs. 1(a)(7), 165(a)-(e), 114 St

of claim for the taxable years 1978, 1981, and 1982 pursuant to 11 U.S.C. sec. 505(a)(1) (1994) (Bankruptcy Code). P Sharon filed an objection to R's proofs of claim on the grounds that she is an innocent spouse pursuant to sec. 6013(e), I.R.C., and sec. 6004 of the Technical and Miscellaneous Revenue Act of 1988, Pub. L. 100-647, 102 Stat. 3342, 3685. The bankruptcy court determined, inter alia, that P Sharon was not a so- called innocent spouse and was liable for the taxes for 1981 and 1982. P

79. The Deficit Reduction Act of 1984, Pub. L. 98-369, sec. 424(a), 98 Stat. 494, 801-802, amended sec. 6013(e) retroactively to all open tax years to which the 1954 Code applies. Petitioner argued in the alternative that she met the requirements of sec. 6004 of the Technical and Miscellaneous Revenue Act of 1988, Pub. L. 100-647, 102 Stat. 3342, 3685-3686. We need not consider this alternative argument. - 25 - sec. 6013(e)(1)(A); (2) there was a substantial understatement of tax attributable to

of the Model Rules of Professional Conduct (Model Rules) in not disclosing certain information petitioner alleges is relevant to that question; and (3) that petitioner is entitled to relief as an innocent spouse pursuant to the transitional rule of section 6004 of the Technical and Miscellaneous Revenue Act of 1988 (TAMRA), 4(...continued) holding that such deductions were not attributable to "grossly erroneous items" rendered it unnecessary for us to decide whether petitioner satisfied the othe

of the Model Rules of Professional Conduct (Model Rules) in not disclosing certain information petitioner alleges is relevant to that question; and (3) that petitioner is entitled to relief as an innocent spouse pursuant to the transitional rule of section 6004 of the Technical and Miscellaneous Revenue Act of 1988 (TAMRA), 4(...continued) holding that such deductions were not attributable to "grossly erroneous items" rendered it unnecessary for us to decide whether petitioner satisfied the othe