gross income which is properly includable exceeded twenty-five percent of the amount of gross income stated in the return); Sanders v. United States, 509 F.2d 162 (5th Cir.1975) (fairly high and generally improving standard of living, limited participation in financial affairs of the family, impaired cognitive facilities, and complexity of spouse’s finances established taxpayer had no reason to know); Cain v. Commissioner of Internal Revenue, 460 F.2d 1243 (5th Cir.1972) (wives relieved of liability because the amount omitted from gross income exceeded twenty-five percent of the gross income reported and the wives neither knew nor had reason to know of the omissions). Fifth Circuit cases disallowing innocent spouse relief include: Parker v. United States, 524 F.2d 479 (5th Cir.1975) (<HOLDING>); Allen v. Commissioner of Internal Revenue,
holding that the deceased defendant trustees wife was a representative of her husbands estate and a proper party for substitution purposes where the wife was the primary distributee of her deceased husbands estate holding the test for foreseeability is whether the wife knew or should have known of her husbands proclivities holding that property held by husband and wife in tenancy by entirety cannot be reached by husbands creditors absent fraud holding wife would have benefitted from the husbands fraudulent omission of income had the fraud not been detected in this case holding that a wife is not liable simply by virtue of the marital relationship for her husbands fraudulent acts