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T.C. at 367; sec. 1.6013-5(b), Income Tax Regs. Normal support
is determined by the circumstances of the parties. Sanders v.
United States, 509 F.2d 162, 168 (5th Cir. 1975); Estate of Krock
v. Commissioner, supra at 678-679; Flynn v. Commissioner, supra
at 367.
Another factor to consider is whether the spouse seeking
relief had been deserted by, or divorced or separated from, the
culpable spouse. Sec. 1.6013-5(b), Income Tax Regs. Yet, this
is only one of the factors to be considered, and section 6013(e)
relief is not limited to spouses whose marriage has ended. Mysse
v. Commissioner, 57 T.C. 680, 700 (1972). A third factor is
whether probable future hardships would be visited upon the
innocent spouse if she is not relieved of liability. Sanders v.
United States, 509 F.2d at 171 n.16.
Petitioner received the gifts of jewelry, and Mr. Womack
provided the funds for her breast implants. Petitioner has not
shown that these expenditures were normal support. Neither has
petitioner shown this liability would pose a hardship to her. We
hold that it would not be inequitable to hold petitioner liable.
In keeping with the above,
Decision will be entered
for respondent.
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