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1993 of erroneous deductions with respect to Laurel Valley Farms,
the Three Crowns Hotel, Azure Tides, Inc., Georgetown Square, and
the Three Crowns Hotel Back Court.10 In the notice for the tax-
able years at issue, respondent also made determinations for one
or more of the taxable years 1989, 1991, 1992, and 1993 of
(1) omitted income with respect to Georgetown Square, (2) omitted
interest income with respect to Monsour Medical Center, and
(3) omitted income relating to unexplained deposits into (a) the
joint bank accounts of petitioner and Mr. Monsour, (b) a separate
bank account of petitioner (petitioner’s separate bank account),
and (c) a bank account that petitioner maintained with respect to
her law practice (petitioner’s law practice bank account).11 In
that notice, respondent also made determinations for one or more
10The record does not establish the respective amounts of
respondent’s determinations of erroneous deductions with respect
to Laurel Valley Farms, the Three Crowns Hotel, Azure Tides,
Inc., Georgetown Square, and the Three Crowns Hotel Back Court.
Nor does the record establish to which of the taxable years 1989,
1991, 1992, and 1993 those determinations pertain.
11The record does not establish the respective amounts of
respondent’s determinations of omitted income with respect to
Georgetown Square, Monsour Medical Center, the joint bank ac-
counts of petitioner and Mr. Monsour, petitioner’s separate bank
account, and petitioner’s law practice bank account, although, as
discussed below, the record shows that respondent made a determi-
nation of omitted income relating to petitioner’s law practice
bank account in an amount between $8,000 and $10,000. Nor does
the record establish to which of the taxable years 1989, 1991,
1992, and 1993 those determinations pertain, although, as dis-
cussed below, the record shows that respondent made a determina-
tion of omitted income relating to petitioner’s law practice bank
account for two of the three taxable years 1991, 1992, and 1993.
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