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repairs and improvements to her residence; she paid down the
mortgage; she paid her and Mr. Mitchell’s medical bills; and she
paid her children’s loans and college expenses. She also
established a trust for her children in the amount of $132,000.
Her spending over the 3 years 1992 through 1994, including the
trust fund, totaled more than $570,000. In short, she used the
money from the transfer refund to the considerable benefit of
herself and her family. These expenditures, while no doubt
generous and well intentioned, nevertheless indicate the receipt
of income far in excess of that previously available as normal
support. See Terzian v. Commissioner, 72 T.C. 1164, 1172 (1979)
(cited in Butler v. Commissioner, supra at 291). We therefore
conclude that respondent did not abuse his discretion in denying
petitioner relief under section 6015(f).
To reflect the foregoing,
Decision will be entered
for respondent.
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