- 38 - 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 disclosedPage: Previous 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 Next
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