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income, standard of living, and spending patterns; and the
culpable spouse's evasiveness and deceit concerning the couple's
finances. Stevens v. Commissioner, 872 F.2d 1499, 1505 (11th
Cir. 1989), affg. T.C. Memo. 1988-63; Flynn v. Commissioner, 93
T.C. 355, 365-366 (1989). Factors to consider in determining
whether it would be inequitable to hold the taxpayer liable
include: (1) Whether the taxpayer seeking relief significantly
benefited from the erroneous items (Purificato v. Commissioner, 9
F.3d 290, 296 (3d Cir. 1993), affg. T.C. Memo. 1992-580; Estate
of Krock v. Commissioner, 93 T.C. 672, 677 (1989)); (2) whether
the spouse seeking relief had been deserted by, or divorced or
separated from the culpable spouse (sec. 1.6013-5(b), Income Tax
Regs.); and (3) whether probable future hardships would be
visited upon the innocent spouse if she is not relieved of
liability (Sanders v. United States, 509 F.2d 162, 171 n.16 (5th
Cir. 1975)).
Respondent's 1993 interrogatories and requests for documents
were designed to elicit information concerning these factors. In
petitioners' October 21, 1993, answers to respondent's
interrogatories, petitioners provided information on petitioners'
educational levels and marital status, and that petitioner wives
handled the household finances. Petitioners declined to answer
respondent's interrogatories regarding their assets and
expenditures. In their responses to respondent's requests for
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