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exorbitant. More important, Mrs. Hemmings played no role in the
family's business and/or investments. She did not even control
the income from her assets. While she was not subject to any
abuse, it is obvious that Mr. Hemmings totally dominated the
financial side of the marriage. It is true that Mr. Hemmings did
not attempt to deceive her and told her that the losses were part
of a tax deferral strategy. But, she also relied on Mr. Harris,
who was a certified public accountant and had prepared the
Hemmingses' and Mr. Brown's tax returns in the past. In this
regard, we note that the Hemmingses' tax returns are extremely
complex in which large gains and losses were reported for other
trading activities. Considering all of the circumstances
concerning these returns, we do not believe that Mrs. Hemmings
had any reason to know that there were substantial
understatements of tax on these returns.
C. Equitable Considerations
The final question is whether, taking into account the facts
and circumstances, it would be inequitable to hold Mrs. Hemmings
liable for deficiencies attributable to the substantial
understatements. Sec. 6013(e)(1)(D). We are primarily concerned
whether Mrs. Hemmings significantly benefited from the erroneous
items. Belk v. Commissioner, 93 T.C. 434, 440 (1989); see also
sec. 1.6013-5(b), Income Tax Regs. 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); sec.
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