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1994 return, we find his bare assertions, without any other
support, an insufficient basis on which to attempt an allocation
of the five dependency exemptions to him, especially in light of
the fact that Ms. Wiest had income of $42,234, as compared to his
income of $29,904, in 1994. If no allocation is attempted, the
benefit of the five exemptions is effectively split equally
between petitioner and Ms. Wiest, since the total liability for
1994 reflects the benefit of the dependency exemptions claimed on
the return and accepted. In the circumstances of this case,
splitting the benefit of the five dependency exemptions equally
is appropriate.
Using the foregoing principles, petitioner’s and Ms. Wiest’s
respective shares of the underpayment could fairly be apportioned
as follows. The gross income of $72,138 reported on the 1994
return consisted of petitioner’s wages of $29,904 and Ms. Wiest’s
wages of $42,234. The reported total tax liability was $8,675.
Petitioner’s share of the total tax liability was $3,596
(($29,904 � $72,138) x $8,675), and Ms. Wiest’s was $5,079
(($42,234 � $72,138) x $8,675). Petitioner’s share of the
underpayment equals his share of the total liability ($3,596)
less his withholdings ($2,696), or $900. The remaining portion
of the underpayment ($3,162) is attributable to Ms. Wiest. We
therefore reject petitioner’s contention that the underpayment is
entirely attributable to Ms. Wiest, as well as respondent’s
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