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conclude that Linda did not know, and had no reason to know, of
the substantial understatement of tax attributable to the
omission from gross income.
III. Inequity Requirement
Linda must prove that, taking into account all the facts and
circumstances, it would be inequitable to hold her liable for the
deficiency. Sec. 6013(e)(1)(D). In determining whether it would
be inequitable to hold Linda liable, we consider whether she
"significantly benefitted" from the understatement of tax.
Buchine v. Commissioner, 20 F.3d 173, 181 (5th Cir. 1994), affg.
T.C. Memo. 1992-36; Belk v. Commissioner, 93 T.C. 434, 440
(1989); sec. 1.6013-5(b), Income Tax Regs. Normal support is not
considered a significant benefit. Terzian v. Commissioner, 72
T.C. 1164, 1172 (1979); sec. 1.6013-5(b), Income Tax Regs. We
consider the lifestyle to which the taxpayer is accustomed when
considering what constitutes normal support. Sanders v. United
States, supra at 168; Belk v. Commissioner, supra.
Respondent contends that Linda significantly benefited from
the understatement, because in 1989 Ronnie bought her a $23,000
Cadillac. At trial, the Court asked Linda's counsel to explain
why the Cadillac did not constitute a substantial benefit to
Linda. Linda's counsel failed to adequately address this
question. Moreover, Linda failed to address this issue in both
her opening and reply briefs. In essence, Linda did not present
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