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the joint return results from concealment, overreaching, or any
other wrongdoing on the part of the other spouse. Alt v.
Commissioner, 119 T.C. 306, 314 (2002), affd. 101 Fed. Appx. 34
(6th Cir. 2004). We also consider factors utilized in
determining “inequity” in the context of section 6015(f).5
Normal support is not considered a significant benefit. Estate
of Krock v. Commissioner, 93 T.C. 672, 678 (1989). Where the
electing spouse’s standard of living remains constant,
significant benefit may still be found if the tax savings are
“immensely beneficial”. Jonson v. Commissioner, 118 T.C. 106,
119-120 (2002), affd. 353 F.3d 1181 (10th Cir. 2003).
Because, as stated previously, petitioner’s standard of
living remained constant throughout the years in issue and
because the claimed tax refunds and savings were not needed or
used to support petitioner but were returned to the Hoyt
partnerships by Glenn, petitioner received no benefit as a result
of the erroneously claimed Hoyt partnership-related tax benefits.
Respondent contends that petitioner could have received a
significant benefit from the refunds even though they were
reinvested and cites Capehart v. Commissioner, T.C. Memo. 2004-
5Rev. Proc. 2000-15, sec. 4.03, 2000-1 C.B. 447, 448-449,
lists nonexclusive factors to be considered in determining
whether it is inequitable to hold the electing spouse liable for
all or part of a deficiency under sec. 6015(f).
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