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other items. We have rejected petitioner’s contention that “she
had neither knowledge nor reason to know of the nonpayment” of
the tax shown due in the 1998 joint return. Assuming arguendo
that we had accepted that contention, whether petitioner knew or
had reason to know when she signed the 1998 joint return that the
$38,324 of tax shown due in that return would not be paid has
nothing to do with, and does not establish, whether she signifi-
cantly benefited from that unpaid 1998 liability.
In further support of her position that the significant
benefit negative factor set forth in section 4.03(2)(c) of
Revenue Procedure 2000-15 is not present here, petitioner as-
serts:
Respondent contends that Petitioner’s trips,
combined with certain personal expenditures, evidenced
significant benefits from the unpaid tax liability.
Although the Petitioner did take the trips in question,
she was on many occassions [sic] doing so for the
primary purpose of correcting failed knee surgery.
Other trips, such as the one to France with her daugh-
ter, were jointly purchased by the Intervenor and
Petitioner. Similarly, the Intervenor also enjoyed
golf trips and a spiritual retreat in California during
the tax year at issue. Payment of Petitioner’s initial
legal fees by Intervenor should similarly be rejected
as a significant benefit since she was doing so only to
protect her best interests and defending herself
against the actions of Intervenor and his counsel. All
of the above Petitioner’s expenditures were being done
at a time of dramatically increasing household income.
Therefore, Petitioner did not significantly benefit
from payment of these costs since the majority of these
expenditures were to protect her health or legal inter-
ests. * * * [Citations omitted.]
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