- 10 - petitioner did not significantly benefit from the embezzlement income. As stated above, Rev. Proc. 2000-15, supra, states that the significant benefit factor can only favor respondent. In contrast, in cases decided under section 6013(e) in which the spouse seeking relief did not significantly benefit from the omitted income or erroneous deductions attributable to the other spouse, the fact that the taxpayer did not significantly benefit weighed in favor of granting relief. See, e.g., Belk v. Commissioner, 93 T.C. 434, 440-441 (1989); Foley v. Commissioner, T.C. Memo. 1995-16; Robinson v. Commissioner, T.C. Memo. 1994- 557; Klimenko v. Commissioner, T.C. Memo. 1993-340; Hillman v.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
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