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aside money into passbook savings accounts, Government savings
bonds, CD's, and retirement plans for themselves and their
children. Mrs. Quinn has assisted her children financially when
needed, the largest sum at any one time being $3,000 to help her
younger daughter purchase a house. Nothing in the record
indicates an increase in spending or a large increase in assets
during or after the years at issue.
Based on these facts, we hold that Mrs. Quinn did not know
and had no reason to know of any understatements of income on
the Quinns' Federal income tax returns for the taxable years
1979, 1980, or 1981.
Ineguity of Holding Mrs. Quinn Liable
Mrs. Quinn contends that it would be inequitable to hold
her liable for the tax deficiency arising from the
understatements because she has not benefited from the omitted
income. Respondent's position is that it would not be
inequitable, since Mrs. Quinn has not proved she did not
benefit.
Nothing suggests a significant benefit accrued to Mrs.
Quinn as a result of the understatement of Mr. Quinn's income.
Mrs. Quinn continued her usual frugal spending and savings
habits. See Dakil v. United States, 496 F.2d 431 (10th Cir.
1974). The large volume of financial documents submitted by Mrs.
Quinn fails to indicate any large or unusual amounts being
deposited into her accounts, or into those she previously held
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