From Charlie Abut at New Jersey Family Law:
The wife was not eligible for the benefits of "Innocent Spouse" treatment under Internal Revenue Code Section 6015. Thus, the tax penalties, interest and liabilities in question were not solely attributable to the husband. The wife was deemed to have had actual knowledge of the understatements of income. This was because she was college-educated, she had access to the parties' joint bank accounts, she balanced the parties' checkbook, she admitted to her status as a member of the parties' Limited Liability Partnership, and she failed to satisfy her duty to make diligent inquiry. Golden et ux., v Commissioner, TC Memo 2007-299, October 8, 2007.