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          Rev. Proc. 2000-15 includes the statement that the significant              
          benefit factor can only favor respondent, this Court has held               
          that the fact the requesting spouse did not significantly benefit           
          can weigh in favor of the requesting spouse.  This is because               
          caselaw under former section 6013(e)(1)(D) considered the fact              
          that the taxpayer did not significantly benefit as a factor in              
          favor of granting relief to that taxpayer.  Ewing v.                        
          Commissioner, 122 T.C. at 45; Ferrarese v. Commissioner, T.C.               
          Memo. 2002-249; see also Mitchell v. Commissioner, 292 F.3d 800,            
          806 (D.C. Cir. 2002) (cases deciding whether a taxpayer was                 
          entitled to equitable relief under former section 6013(e)(1)(D)             
          are helpful in deciding whether a taxpayer is entitled to relief            
          under section 6015(f)), affg. T.C. Memo. 2000-332; Cheshire v.              
          Commissioner, 282 F.3d at 338 n.29.                                         
               Respondent contends that petitioner significantly benefited            
          from the unpaid 1991 through 1999 tax liabilities.  Specifically,           
               15(...continued)                                                       
               considered is whether the person seeking relief                        
               significantly benefitted, directly or indirectly, from                 
               the items omitted from gross income.  However, normal                  
               support is not a significant ‘benefit’ for purposes of                 
               this determination.  Evidence of direct or indirect                    
               benefit may consist of transfers of property, including                
               transfers which may be received several years after the                
               year in which the omitted item of income should have                   
               been included in gross income.  Thus, for example, if a                
               person seeking relief receives from his spouse an                      
               inheritance of property or life insurance proceeds                     
               which are traceable to items omitted from gross income                 
               by his spouse, that person will be considered to have                  
               benefitted from those items.  * * *                                    
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