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petitioner and Mr. Goings made substantial real estate purchases,
presumably using, at least in part, funds received from Bordelon.
Her attempts to explain such purchases are unpersuasive.
Moreover, petitioner has not established that such benefits were
consistent with her then-existing lifestyle, nor has she
established that they constituted normal support.
When assessing whether it would be inequitable to hold
petitioner liable for the deficiencies attributable to Mr.
Going's receipt of unreported income, we also consider whether
petitioner was deserted or divorced subsequent to that activity.
Although petitioner and Mr. Goings were divorced in 1993, we find
that such circumstance does not outweigh the significant benefits
petitioner received from the omitted kickback income.
Furthermore, petitioner has not established that any hardship she
would encounter as a result of incurring liability for the
deficiencies attributable to the omission of the kickback income
from the joint returns at issue would make it inequitable to hold
her jointly liable for those deficiencies.
Accordingly, we find that it would not be inequitable to
hold petitioner liable for the understatements attributable to
the funds Mr. Goings received from Bordelon during the taxable
years at issue.
Because petitioner has failed to satisfy all of the
conjunctive factors set forth in section 6013(e)(1), we hold that
she does not qualify for "innocent spouse" relief and is
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