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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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