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Further, in light of the frequent physical abuse by
Mr. Makalintal and Mr. Makalintal’s general refusal to discuss
his business and financial affairs with petitioner, we believe
that petitioner's inquiry was reasonable and sufficient to
satisfy her duty of inquiry with regard to the taxable income
reported on Mr. Makalintal's and her 1986, 1987, and 1988 joint
Federal income tax returns. See Price v. Commissioner, supra at
966.
The final element in considering whether petitioner
qualifies for innocent spouse relief is whether, in light of all
of the facts and circumstances, it would be inequitable to hold
petitioner liable for the alleged understatement for 1986
relating to the sale of the ICPI stock and for the substantial
understatements for 1987 and 1988 that we have sustained relating
to the deposits into Mr. Makalintal and petitioner’s bank
accounts. Sec. 6013(e)(1)(D); Flynn v. Commissioner, 93 T.C.
355, 367 (1989); sec. 1.6013-5(b), Income Tax Regs. This issue
turns largely on the question of whether petitioner benefited
directly or indirectly from the understatements of tax. Flynn v.
Commissioner, supra at 367; Bell v. Commissioner, T.C. Memo.
1989-107; sec. 1.6013-5(b), Income Tax Regs. Normal support of a
spouse and children is not regarded as a significant benefit and
is to be considered in light of the circumstances of the parties.
Sanders v. United States, 509 F.2d 162, 168 (5th Cir. 1975);
Flynn v. Commissioner, supra at 367; Bell v. Commissioner, supra.
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