Your client filed a joint return with her spouse and later receive a letter from the IRS indicating that $150,000 in income was not reported. Your client finds out that it was money her ex earned (dealing drugs) during the marriage that he failed to report - and she didn't know a thing about it.

Write a short memorandum to your client and advise her of any code section you find that can help. Be sure to in provide a step by step analysis of why this provision can or cannot provide relief to her.