E. Carolyn Mellen - Page 38




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            above and restate here that whether a spouse requesting relief                              
            under section 6015(f) knew or had reason to know of the item                                
            giving rise to a deficiency is relevant in determining whether                              
            such spouse is entitled to such relief.                                                     
                  With respect to the significant benefit negative factor set                           
            forth in section 4.03(2)(c) of Revenue Procedure 2000-15 (i.e.,                             
            whether the requesting spouse has significantly benefited beyond                            
            normal support from the unpaid liability or item giving rise to                             
            the deficiency), petitioner contends on brief that she did not                              
            significantly benefit from the item giving rise to the deficiency                           
            because it “did not significantly increase her wealth, her                                  
            standard of living, or provide any meaningful benefit in excess                             
            of the support she is otherwise entitled to receive from her                                
            spouse under state law.”                                                                    
                  We find on the instant record that petitioner has failed to                           
            establish the amount that she and Mr. Mellen expended annually                              
            for their normal support during 1994, 1995 (the year to which the                           
            unpaid liability at issue relates), and thereafter.  Nonetheless,                           
            it is reasonable to assume that the amount that they expended                               
            annually for such support during 1994 and 1997 through 2001 did                             
            not exceed their annual net income (i.e., the total of peti-                                
            tioner’s net compensation from Questar, Mr. Mellen’s disability                             
            benefits, and any interest, dividends, and other income disclosed                           








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