QUESTION: Which of the following elements of innocent spouse relief is the most difficult to prove
A. Joint return may have been filed
B. The joint return must contain an understatement of tax attributable to an erroneous item of the other spouse
C. The spouse seeking relief must establish that he or she did not know, and did not have any reason to know, when he or she signed the return that there was an understatement of tax
D. The requesting spouse must elect innocent spouse relief no later than two year after the IRS begins collection activity against that spouse.