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known Gelda for many years, trusted him, and knew that he had
prepared the Forms 1040. In addition, Gerald assured petitioner
that Gelda properly prepared the Form 1040 and that it presented
no problem for her. We conclude that petitioner did not know,
and did not have reason to know, that the deductions would give
rise to a substantial understatement.
In determining whether it would be inequitable to hold
petitioner jointly liable for the deficiencies, we consider
whether she significantly benefited from the erroneous items of
the other spouse. 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). Any significant benefit
received by petitioner must be considered in the totality of the
circumstances. Busse v. United States, 542 F.2d 421, 427 (7th
Cir. 1976). Normal support is not considered a significant
benefit. Belk v. Commissioner, 93 T.C. 434, 440 (1989). We look
at the lifestyle to which the taxpayer is accustomed when
considering what constitutes normal support. Id.
Gerald invested in his businesses the tax savings derived
from the tax shelter investments. The tax savings were not used
to better petitioner's standard of living. Gerald sold his
business interests in 1984 and 1985, and petitioner received no
proceeds from those sales.
Petitioner's family vacations and use of the pleasure boat
were consistent with the lifestyle to which the Jacobys had
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