- 22 - hardships that would be imposed on the spouse seeking relief, if such relief were denied. Sanders v. United States, supra. Petitioner contends that she did not enjoy any economic benefit beyond normal support from the understatement. In support of her contention, petitioner claims that Emmens "never spent any money on her" and that Emmens' girlfriends benefitted from his unreported income. This contention overlooks the fact that petitioner moved to a new house, drove a new Cadillac, occasionally utilized the planes and boats from the drug smuggling operation for personal and social use, and generally lived a lifestyle that exceeded normal support. Considering all the facts and circumstances involved herein, we conclude that it would not be inequitable to hold petitioner liable for the determined understatement. Accordingly, we hold that petitioner is not an innocent spouse under section 6013(e). Issue 2. Addition to Tax for Fraud Respondent determined that petitioner is liable for the addition to tax for fraud under section 6653(b) for the years at issue. Petitioner asserts that she is not liable for the addition to tax for fraud because she lacked fraudulent intent and had no knowledge of Emmens' illegal activities. If any part of an underpayment is due to fraud, a taxpayer is liable for an addition to tax equal to 50 percent of thePage: Previous 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Next
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