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determine whether a spouse significantly benefited from the
erroneous item; however, this factor is still considered in
determining whether it is inequitable to hold a spouse liable.
Purcell v. Commissioner, 86 T.C. at 242; Johnson v. Commissioner,
T.C. Memo. 1993-227. Normal support is not a "significant
benefit" for purposes of determining whether denial of innocent
spouse relief would be inequitable under section 6013(e)(1)(D).
Terzian v. Commissioner, 72 T.C. 1164, 1172 (1979); sec.
1.6013-5(b), Income Tax Regs. Normal support is measured by the
circumstances of the parties. See Sanders v. United States, 509
F.2d 162, 168 (5th Cir. 1975). Petitioner bears the burden of
proving that she received no significant benefit from the
understatements other than normal support, and this burden must
be satisfied with specific facts regarding lifestyle
expenditures, asset acquisitions, and dispositions of the
benefits of the understatements. Estate of Krock v.
Commissioner, 93 T.C. 672 (1989).
Respondent contends that it would not be inequitable to hold
petitioner liable for the deficiency attributable to the
understatement because petitioner significantly benefited from
the omitted income during 1988. Respondent further argues that
it would not be inequitable to hold petitioner liable because she
received significant benefits from the refund check received.
In contrast, petitioner contends that she experienced no
significant benefit with respect to either the omitted income
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