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spouse status because she failed to prove that it would be
inequitable to hold her liable.
In deciding whether it is inequitable to hold a spouse
liable for a deficiency, we consider whether the purported
innocent spouse "significantly benefited", either directly or
indirectly, from the unreported income. Hayman v. Commissioner,
992 F.2d 1256, 1262 (2d Cir. 1993), affg. T.C. Memo. 1992-228;
Belk v. Commissioner, 93 T.C. 434, 440 (1989); Purcell v.
Commissioner, 86 T.C. 228, 241 (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); sec. 1.6013-5(b), Income Tax Regs. We
consider the lifestyle to which the taxpayer is accustomed when
considering what constitutes normal support. Sanders v. United
States, 509 F.2d at 168; Belk v. Commissioner, supra.
It is also relevant to consider whether the spouse claiming
relief has been deserted, divorced, or separated. Sec. 1.6013-
5(b), Income Tax Regs. We note that petitioner is now divorced
from Emmens and has since remarried. We further recognize,
however, that petitioner was not divorced from Emmens until 1994,
after he had entered into a plea agreement for violation of
section 7201. The provisions of this plea agreement included the
dismissal of all criminal counts of tax liability against
petitioner. In addition, we examine the probable future
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