All of the Following Requirements Must Be Met in Order

All of the following requirements must be met in order to establish innocent spouse relief except which of the following?

A) The return contains an understatement of tax attributable to the erroneous item(s) of an individual filing it.
B) Based on all the facts and circumstances, holding the other individual for the deficiency would be inequitable.
C) The request for innocent spouse relief is made no later than one year after the IRS begins its collection efforts.
D) The requesting individual establishes that he or she neither knew nor had reason to know of any or all of the understatement.