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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