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bounds of normal support. See, e.g., Foley v. Commissioner, T.C.
Memo. 1995-16.
In evaluating the equity holding a spouse liable under
section 6013(e), we also consider the probable future hardship on
the spouse seeking relief if that spouse is required to pay the
tax. Sanders v. United States, 509 F.2d at 171 n.16; Makalintal
v. Commissioner, T.C. Memo. 1996-9. The evidence before the
Court indicates that there will be substantial hardships if we
deny relief in this case. Petitioner's standard of living has
decreased significantly from the time of the divorce. In 1994,
petitioner reported adjusted gross income of less than $13,000.
Further, petitioner has periodically received financial assis-
tance from her elder son. Respondent points out that petitioner
received substantial assets in the divorce. However, the
property located at Hangman Valley Road, by far the most signifi-
cant asset petitioner received in the divorce, was sold in 1989
for barely more than 50 percent of its assigned value in the
property settlement agreement.
Nonetheless, respondent argues that it would not be
inequitable to hold petitioner liable because, under the property
settlement agreement incident to the divorce, Thomas Dillon
indemnified petitioner against any losses resulting from tax
liabilities arising from returns filed prior to 1987. The record
indicates, however, that Mr. Dillon does not have the money to
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