A New York State Administrative Law Judge has granted innocent spouse relief under Tax Law § 654 to a wife whose husband pled guilty to filing false New York State and City corporation franchise tax returns understating income from restaurants he owned, and also admitted deliberately failing to remit sales taxes collected at those restaurants. Matter of Vishni Schiro Withanachchi, DTA No. 825394 (N.Y.S. Div. of Tax App., Dec. 18, 2014). Although Mrs. Withanachchi signed the personal income tax returns in question, the ALJ found that even a careful review of the returns would not have revealed the fraud, that she had no reason to know of the understatement of income from her husband’s business, and that there were no unusual or lavish expenditures during the audit years that could have put her on notice of the hidden income. The ALJ also noted that both spouses, although U.S. citizens, were born in Sri Lanka, where the culture defined the male role as handling all financial matters, and that liability for the taxes would create even more difficulties for a family already facing severe economic hardship.