- 58 -
6013(e)(1)(D); Flynn v. Commissioner, 93 T.C. 355, 367 (1989);
sec. 1.6013-5(b), Income Tax Regs. A factor to be considered is
whether the purported innocent spouse significantly benefited
beyond normal support, either directly or indirectly, as a result
of the unreported income. Hayman v. Commissioner, 992 F.2d at
1262; Belk v. Commissioner, 93 T.C. at 440; Purcell v.
Commissioner, 86 T.C. 228, 242 (1986); sec. 1.6013-5(b), Income
Tax Regs. Normal support is determined by the circumstances of
the taxpayers. See Sanders v. United States, 509 F.2d at 168;
Estate of Krock v. Commissioner, 93 T.C. 672, 678 (1989); Flynn
v. Commissioner, supra. Petitioners bear the burden of proving
that Ms. Walters received no significant benefit from the
understatement other than normal support, and that burden must be
satisfied with specific facts regarding lifestyle, expenditures,
asset acquisitions, and the disposition of the benefits of the
understatement. See Bokum v. Commissioner, 94 T.C. at 157;
Estate of Krock v. Commissioner, supra.
Petitioners contend that Ms. Walters did not benefit
significantly from the unreported income but rather received
merely ordinary support that was commensurate with the upper
middle class lifestyle that petitioners had maintained before the
embezzlement. They assert that Ms. Walters herself was not
extravagant in her spending habits. Petitioners contend further
that the Camelot benefited FIP through the entertainment of its
clients and does not demonstrate an extravagant lifestyle. They
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