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circumstances of taxpayers. Sanders v. United States, 509 F.2d
162, 168 (5th Cir. 1975); Flynn v. Commissioner, 93 T.C. 355, 367
(1989).
Evidence of direct or indirect benefits may consist of
property transfers, including transfers received several years
after the year in which the erroneous deductions were claimed.
See sec. 1.6013-5(b), Income Tax Regs. This would include the
division of property in a subsequent divorce proceeding.
Pettinato v. Commissioner, T.C. Memo. 1995-85. Finally, in
deciding whether it is equitable to hold a spouse liable for
deficiencies or "innocent" under section 6013(e), we are to
consider the probable future hardships that would be imposed on
the spouse seeking relief, if such relief was denied. Sanders v.
United States, supra at 171 n.16; Dakil v. United States, 496
F.2d 431, 433 (10th Cir. 1974).
Petitioner admits that her lifestyle may have been
considered lavish, but it was the standard she had enjoyed during
her marriage with Philip. Respondent contends that petitioner
and Philip entered into the marriage on a relatively equal
financial footing and that any benefits to petitioner were earned
and consumed during the marriage and the years in issue.
Petitioner also contends that Philip gambled away the tax shelter
benefits. The tax benefits in question stem from a 1983
transaction for which losses were claimed for 1983, 1984, and
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