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drawn on the Reaves Livestock account at Southern National and
the First Citizens accounts. She should have known about the
understatements resulting from the personal expenses paid from
the First Citizens accounts that petitioners conceded.
3. Not Inequitable To Hold Mrs. Reaves Liable
To be entitled to relief as an innocent spouse, Mrs. Reaves
must show that it would be inequitable to hold her liable for
the deficiencies in tax for the years in issue. Sec.
6013(e)(1)(D).
In deciding whether it is inequitable to hold a spouse
liable for a deficiency, we consider whether the purported
innocent spouse significantly benefited beyond normal support,
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. at 242; H. Rept. 98-432
(Part 2) 1501, 1502 (1984); sec. 1.6013-5(b), Income Tax Regs.
Normal support is determined by the circumstances of the
taxpayers. Sanders v. United States, 509 F.2d 162 (5th Cir.
1975); Estate of Krock v. Commissioner, 93 T.C. 672, 678 (1989);
Flynn v. Commissioner, 93 T.C. 355, 367 (1989).
Mrs. Reaves contends that she did not benefit from the
substantial understatement of income by her husband or receive
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