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We find that Mrs. Garrett has failed to show that it would
be inequitable to hold her jointly and severally liable for the
disputed taxes. An important factor in determining whether it is
inequitable to hold a spouse liable is whether that spouse
significantly benefited, either directly or indirectly, from the
understatement of taxes. Belk v. Commissioner, 93 T.C. 434, 440
(1989); Purcell v. Commissioner, 86 T.C. 228, 242 (1986), affd.
826 F.2d 470 (6th Cir. 1987); 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). Mrs. Garrett bears
the burden of proving that she received no significant benefit
from the unreported income other than normal support, and this
burden must be supported with specific evidence of lifestyle
expenditures, as well as asset acquisitions. Bokum v.
Commissioner, 94 T.C. at 157; Estate of Krock v. Commissioner, 93
T.C. 672, 681 (1989).
Mrs. Garrett failed to provide any evidence of lifestyle
expenditures or asset acquisitions. In fact, she did not even
testify at trial. Thus, Mrs. Garrett failed to show that she did
not significantly benefit from the understatements in a manner
that was above her normal support.
Moreover, Mr. Garrett signed an indemnification agreement
promising to pay all tax liabilities resulting from the filing of
their joint tax returns through 1992. The effect of such a
promise has been considered by this Court on several occasions
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