Sherry P. Aude - Page 26

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          relief, any participation in the wrongdoing on the part of the              
          innocent spouse, and the effect of a subsequent divorce or                  
          separation.  See S. Rept. 91-1537 (1970), 1971-1 C.B. 606, 607-             
          608.                                                                        
               While the text of section 6013(e) no longer requires us to             
          determine whether a spouse significantly benefited from the                 
          erroneous item, this factor is still considered to determine                
          whether it is inequitable to hold a spouse liable.  Belk v.                 
          Commissioner, 93 T.C. 434, 440 (1989); Purcell v. Commissioner,             
          86 T.C. 228, 241-242 (1986), affd. 826 F.2d 470 (6th Cir. 1987).            
          In making this determination, normal support, measured by the               
          circumstances of the parties, is not a significant benefit.                 
          Estate of Krock v. Commissioner, 93 T.C. 672, 678 (1989); Terzian           
          v. Commissioner, T.C. at 1172; see sec. 1.6013-5(b), Income Tax             
          Regs.  Unusual support and receipt of property, however, would              
          constitute a significant benefit.  Terzian v. Commissioner, supra           
          at 1172; see sec. 1.6013-5(b), Income Tax Regs.  During the years           
          at issue, petitioner received a $3,000 monthly allowance to take            
          care of the household expenses, which included taking care of               
          five children.  This amount did not increase during this time,              
          but at times, it decreased.  This normal support for household              
          expenditures is not considered to be a significant benefit.                 
          Also, during the same period of time, petitioner's standard of              
          living did not increase in comparison to her standard of living             
          in prior years.  She lived in the same house since 1978.                    




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