- 24 - 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 andPage: Previous 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 Next
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