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other assets may also constitute a significant benefit precluding
the application of innocent spouse relief. Purificato v.
Commissioner, 9 F.3d 290, 296 (3d Cir. 1993), affg. T.C. Memo.
1992-580; Estate of Krock v. Commissioner, supra at 679.
Evidence of a significant benefit includes transfers of property,
including unusual or lavish support or gifts in years after the
one at issue. Estate of Krock v. Commissioner, supra at 679.
Mrs. Meyer received large sums of money from several
corporations owned by her husband, both during and after the year
at issue. See supra pp. 5-6. Moreover, petitioner deposited
into her own account monthly rental income she received from a
tenant living at the Muttontown estate. Although Mrs. Meyer
claimed to drive only a Mercury stationwagon, she had five
automobiles registered in her name, including a Lincoln and two
Lexuses, in the years following 1989. Under these circumstances
the Court determines a significant benefit inured to petitioner
as a result of the understatement of tax and income. See, e.g.,
Levitt v. Commissioner, T.C. Memo. 1995-464; Tabbi v.
Commissioner, T.C. Memo. 1995-463; Stiteler v. Commissioner, T.C.
Memo. 1995-279; Pettinato v. Commissioner, T.C. Memo. 1995-85.
Another factor to consider is whether the spouse seeking
relief has been deserted by, or divorced or separated from, the
alleged culpable spouse. Sec. 1.6013-5(b), Income Tax Regs.
However, relief is not limited to spouses whose marriages have
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