- 28 -
would not have been able to make. See Alt v. Commissioner,
119 T.C. at 314; Jonson v. Commissioner, 118 T.C. at 119-120.
Normal support, which is measured by the circumstances of the
requesting spouse, is not a significant benefit. Flynn v.
Commissioner, 93 T.C. 355, 367 (1989).
On the record before us, we find that petitioner has failed
to establish the amount that the Albins expended annually for
their normal support before, during, and after the subject years.
On that record, we further find that petitioner has failed to
carry her burden of persuading us that she did not significantly
benefit beyond normal support from the shelter loss giving rise
to the deficiency for each subject year. On the record before
us, we find that petitioner has failed to carry her burden of
establishing that this factor is not present in this case. We
hold that this factor is neutral for each of the subject years.
iv. Lack of Economic Hardship
For the reasons stated above in our analysis of the positive
counterpart to this factor, we conclude that petitioner will not
suffer economic hardship from a denial of equitable relief in
each of the subject years. We hold that this factor weighs
against granting equitable relief to petitioner for all of the
subject years.
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