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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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