Anna Ruth French - Page 10

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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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