Anna Ruth French - Page 9

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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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