Sherburne M. Edmondson, Jr. and Diane L. Edmondson - Page 14

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          1171 (1979).  Petitioner bears the burden of proving that she               
          received no significant benefit from the understatement other than          
          normal support, and this burden must be satisfied with specific             
          facts regarding lifestyle, expenditures, asset acquisitions, and the        
          disposition of the benefits of the understatement.  See Estate of           
          Krock v. Commissioner, 93 T.C. 672 (1989).                                  
               It is also relevant to consider whether the spouse claiming            
          relief has been deserted, divorced, or separated.  Kistner v.               
          Commissioner, T.C. Memo. 1995-66; sec. 1.6013-5(b), Income Tax Regs.        
          We also examine the probable future hardships that would be imposed         
          on the spouse seeking relief, if such relief were denied. Sanders           
          v. United States, 509 F.2d 162, 171 (5th Cir. 1975).                        
               While petitioner's standard of living did not increase in 1988         
          in comparison to prior years, the Edmondsons continued living               
          together from 1988 until 1992.  Thus, they shared equally in the tax        
          savings generated by the understatement.  In this regard, part of           
          the disallowed deductions (from which tax savings were derived)             
          related to:  A failed business that both Mr. Edmondson and                  
          petitioner operated; the Floyd Avenue house in which they both              
          lived; and a Mexican trip that benefited petitioner as well as Mr.          
          Edmondson.                                                                  
               The proceeds from the gain on the sale of the Seattle house            
          went to pay living expenses for the entire Edmondson household, as          
          well as the debts of the failed business. Moreover, Mr. Edmondson           
          gave petitioner $500 a month for 36 months following the end of             




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