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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, 440 (1986), affd.
826 F.2d 470 (6th Cir. 1987); sec. 1.6013-5(b), Income Tax Regs.
Evidence of direct or indirect support may consist of transfers
of property, including transfers which may be received several
years after the year in which the omitted income should have been
included in gross income. Sec. 1.6013-5(b), Income Tax Regs.
Mrs. Jones contends that she did not enjoy any economic
benefit beyond normal support, either directly or indirectly,
from the substantial understatement of income by her husband. In
support of her contention, Mrs. Jones points to the fact that
during the years at issue she drove an older model Mercedes with
over 100,000 miles on it, and at the time of trial she was
driving an older model Mercedes with approximately 240,000 miles
on it. Furthermore, in contrast to the $900,000 house she and
petitioner owned until September of 1991, at the time of trial
she and petitioner were living in a house for which they paid
$325,000.
Although Mrs. Jones may now have a less affluent standard of
living than she had during the years at issue, it is not true
that she did not significantly benefit from the understatements
on petitioners' 1989, 1990, and 1991 returns. In 1990 and 1991,
Mrs. Jones received the Winterchase lots and the Papermill Road
property, which had fair market values of $166,904 and $46,794,
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