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instructive to our analysis. Butler v. Commissioner, 114 T.C. at
283. The material factors most often cited and considered are
whether there has been a significant benefit to the spouse
claiming relief, and whether the failure to report the correct
tax liability on the joint return results from concealment,
overreaching, or any other wrongdoing on the part of the other
spouse. Alt v. Commissioner, 119 T.C. at 314; Jonson v.
Commissioner, 118 T.C. at 119. Normal support is not considered
a significant benefit. Jonson v. Commissioner, supra at 119.
Ms. McClelland benefited from the improper interest
deduction to a certain extent. She received rental income from
property that was purchased with the proceeds of Red Wing’s
tugboat sale, and the amount of tax actually owed on that sale
was decreased by the improper interest paid deduction. Any
negative inference we may have drawn from this fact is partially
mitigated by Ms. McClelland’s testimony that the rental income
was to compensate her for past services she provided to Red Wing.
Mr. McClelland also asserts that his payment of her medical
and credit card bills indicates she significantly benefited from
the incorrect deduction. The record fails to support a
conclusion that Ms. McClelland’s medical expenses and credit card
bills were anything other than normal support. The record is
devoid of credible evidence indicating the amount of these
expenditures.
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