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significant benefit, although it remains an important factor.
Hayman v. Commissioner, 992 F.2d at 1262; Estate of Krock v.
Commissioner, supra at 678; sec. 1.6013-5(b), Income Tax Regs.
Normal support, as measured by the circumstances of the
parties, is not considered a significant benefit for purposes of
determining whether denial of innocent spouse relief would be
inequitable under section 6013(e)(1)(D). Flynn v. Commissioner,
93 T.C. at 367; Purcell v. Commissioner, 86 T.C. at 242.
However, a significant benefit may be found where the omitted
income is used not merely to pay a few household expenses, but to
maintain a married couple's "unusual lifestyle". Estate of Krock
v. Commissioner, supra at 683-684. Tax savings, such as those
deriving from the omission of income and the erroneous Schedule C
deduction, constitute a significant benefit as well. Bokum v.
Commissioner, 94 T.C. at 157.
The amount of the understatement in the instant case
provided funding for unusual expenditures and asset acquisitions
for the benefit of petitioner beyond whatever might have been
normal support. See supra pp. 3-4. In sum, petitioner's
lifestyle improved significantly as a result in part of the
constructive dividend income and disallowed Schedule C expenses.
Sanders v. United States, 509 F.2d at 168.
Even if the Court were to credit Mrs. Meyer's self-serving
testimony that the mansion was a "monster" and that she derived
no pleasure from her opulent surroundings, acquiring savings and
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