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Finn and Stella have been married since 2016 and have filed a joint tax return in the past. Both spouses have earned bachelor's degrees from a university. Finn works for the local library and earns $50,000 per year and Stella works as a financial consultant and earns $150,000 per year. Stella handles all the couple's financial affairs including the filing of the income tax return. Finn briefly looks at the return before Stella e-files the return. They are currently being audited by the IRS on their 2021 and 2022 tax returns, and they owe a tax liability and penalty of $210,000. The IRS claims underreported income of $600,000 that Stella earned under the table related to Ponzi schemes she developed. Finn states that he was unaware of the earnings and should not be held liable for any part of the tax liability. Finn drives a Jaguar, the couple purchased a new $1,200,000 home in 2022, and they took several trips to Europe and the Caribbean in 2021 and 2022. Is Finn liable for the tax liability or can he claim innocent spouse relief?
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