- 22 -
discussed above, only Mr. Peterson's evasiveness benefits
petitioner. The weight we attribute to such factor, however,
does not exceed the amount of weight we attribute to any of the
remaining three factors, each of which favors respondent. In
light of the facts of the instant case, we do not think that Mr.
Peterson's evasiveness was of such an extent that petitioner
could not have had reason to know of the understatement of income
in the return.
Section 6013(e)(1)(D)
The next matter we consider is whether it would be
inequitable to hold petitioner liable for the deficiencies in tax
attributable to her former husband's embezzlement activities.
See sec. 6013(e)(1)(D). In answering this question, we take into
account all of the facts and circumstances. Id.; sec.
1.6013-5(b), Income Tax Regs. A factor to be considered is
whether the spouse seeking relief significantly benefited, either
directly or indirectly, from the omitted income. Buchine v.
Commissioner, 20 F.3d 173, 181 (5th Cir. 1994), affg. T.C. Memo.
1992-36; sec. 1.6013-5(b), Income Tax Regs. Normal support,
which is to be measured by a couple's circumstances, is not
considered a significant benefit. Sanders v. United States,
supra at 168; Terzian v. Commissioner, 72 T.C. at 1172; Mysse v.
Commissioner, 57 T.C. at 699. A significant benefit exists if
expenditures have been made which are unusual for the taxpayer's
accustomed lifestyle. Terzian v. Commissioner, supra. Other
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