The petitioners, a married couple, failed to fully report their income on their joint return. The wife worked for an attorney promoter of fraudulent tax schemes, and she put her paychecks into a bank account from which she paid personal living expenses without reporting the wage income. The husband was aware that her income was not being reported and he didn't report his income for one year at issue. The husband sought innocent spouse relief and the court, based on the factors set forth in Rev. Proc. 2013-34, determined that the husband knew of the unpaid tax liability, and denied innocent spouse relief. Williams v. Comr., T.C. Memo. 2015-198.