-14- 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 ofPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 Next
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