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F.2d 1256, 1262 (2d Cir. 1993), affg. T.C. Memo. 1992-228).
Normal support is not considered a significant benefit. Hayman
v. Commissioner, supra at 1262 (citing Flynn v. Commissioner, 93
T.C. 355, 367 (1989)).
Petitioner received significant benefits as a result of
filing a joint return on which the Social Security benefits went
unreported. The joint return filed by the parties reflected
taxable income derived almost exclusively from petitioner.
Filing a joint return with Ms. Morrison allowed petitioner to
significantly reduce his taxable income using exemptions and
itemized deductions attributable to Ms. Morrison, her mother, and
her daughter. Had he not filed the joint return with Ms.
Morrison, petitioner’s tax liability would have been
substantially higher. Further, had Ms. Morrison filed a separate
return properly including her benefits, she would have had
little, if any tax liability. Her tax liability arose when her
benefit income was added to petitioner’s income on the joint
return.
The parties’ failure to report the correct tax liability was
not the result of concealment, overreaching, or any other
wrongdoing on the part of Ms. Morrison. Ms. Morrison was
forthright and never made any attempt to conceal from petitioner
the amount of benefits she received. She presented her benefit
statement to the return preparer while in the presence of
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