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erroneous item; however, this factor is still considered in
determining whether it is inequitable to hold a spouse liable.
Belk v. Commissioner, 93 T.C. 434, 440 (1989); Purcell v.
Commissioner, 86 T.C. 228, 242 (1986), affd. 826 F.2d 470 (6th
Cir. 1987). Normal support is not a significant benefit for
purposes of determining whether denial of innocent spouse relief
would be inequitable under section 6013(e)(1)(D). Estate of
Krock v. Commissioner, 93 T.C. 672, 678 (1989); Terzian v.
Commissioner, supra at 1172; sec. 1.6013-5(b), Income Tax Regs.
Normal support is measured by the circumstances of the taxpayers.
See Sanders v. United States, 509 F.2d 162, 168 (5th Cir. 1975).
Petitioner notes that she and Thomas Dillon enjoyed a high
standard of living that was consistent with Mr. Dillon's level of
earned income, and, therefore, the tax savings did not produce a
benefit beyond their normal level of support. In fact, the tax
savings of $21,579 in 1982 were negligible in comparison to
Mr. Dillon's reported income of more than $425,000.
Another factor to consider is the 1987 divorce between
petitioner and Mr. Dillon. Flynn v. Commissioner, 93 T.C. 355,
367 (1989); sec. 1.6013-5(b), Income Tax Regs. The Dillons had
acquired numerous assets due to Thomas Dillon's success at Dillon
Securities; these assets were distributed evenly in the divorce.
Given the Dillons' relatively high standard of living during
their marriage, their divorce settlement is well within the
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