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during 1988 or the refund check received in 1990. Petitioner
maintains that any benefit that she received from either the
omitted income or the refund check amounted to nothing more than
normal support. We disagree. Even assuming that petitioner
received nothing more than normal support from the omitted income
in 1988, we do not accept petitioner’s contention with respect to
the refund check. As explained above, 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, supra at 1172; sec.
1.6013-5(b), Income Tax Regs. We believe, however, that the
refund check provided petitioner with more than normal support in
1990. Using the funds obtained from the refund check, petitioner
and Mr. French jointly purchased several certificates of deposit
in large denominations. A portion of the money represented by
these certificates of deposit was used for the direct and
individual benefit of petitioner. The remainder, less some
amount used personally by Mr. French, was rolled over into two
certificates of deposit owned individually by petitioner.
Although the record is not entirely clear as to what petitioner
did with these two certificates of deposit, which totaled
$150,000, we are not persuaded by petitioner’s argument that such
funds merely amounted to normal support allotted to her by Mr.
French. In fact, the $150,000 exceeds petitioner’s 1988
estimated family expenses by nearly 50 percent. Moreover, this
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