Barbara A. Vriner, A.K.A. Barbara A. Coyne - Page 7

          the Vriner family was paying some of their expenses such as the             
          house payment.  Petitioner's belief is reasonable in light of Mr.           
          Vriner's close ties with his family and the family business,                
          coupled with the fact that she was privy to no financial                    
          information.  Mr. Vriner reported income from rental property and           
          also received money from the Vriner restaurant, and petitioner              
          reasonably could conclude that Mr. Vriner used those funds to               
          satisfy their monthly expenditures.  There were no unusual or               
          lavish expenditures.  Thus, we conclude that petitioner did not             
          know or have reason to know of the substantial understatements.             
               In determining whether it would be inequitable to hold                 
          petitioner jointly liable for the deficiency in tax for 1987, we            
          consider whether she significantly benefited from the                       
          underpayments of tax.  Estate of Krock v. Commissioner, 93 T.C.             
          672, 677 (1989).  Any benefit received by petitioner must be                
          considered in the totality of the circumstances.  Busse v. United           
          States, 542 F.2d 421, 427 (7th Cir. 1976).  Petitioner received             
          very little, if any, benefit from the funds that gave rise to the           
          deficiency in this case.  Petitioner lived a modest lifestyle and           
          made no extravagant expenditures.  Any benefit she received was             
          in the form of necessities and normal support, with the possible            
          exception of the two trips to California to visit her parents.              
          Normal support is not considered a significant benefit.  Belk v.            
          Commissioner, 93 T.C. 434, 440 (1989).  We conclude that it would           

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