Frank and Sharon have been married for five years. Without Frank’s knowledge, Sharon has been operating an escort service from the local pub. This year’s operations were very profitable. In fact, if Sharon had reported the net escort income, their joint Federal income tax liability would have increased by $50,000. When Sharon finally is nabbed by the police, she is taken to jail. Frank is unable to locate any of Sharon’s earnings in their personal bank or brokerage accounts. Can Frank fend off the IRS’s charge that he should pay the $50,000 in tax, plus interest and penalties, from his salary as an engineer?