Maureen Monsour - Page 27

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          tioner’s Form 8857:                                                         
                    The understatement in tax for the periods in ques-                
               tion were due to investments and business activities of                
               my husband, [about] all of which I had no information                  
               or knowledge.                                                          
                    During these periods I had employment and educa-                  
               tional pursuits totally unrelated to my husband’s in-                  
               vestment and business activities.  All of the under-                   
               statements in question were the results of an audit of                 
               our tax return.                                                        
               On September 12, 2002, in response to petitioner’s Form                
          8857, respondent issued to petitioner a notice of determination.            
          In that notice, respondent denied petitioner’s request for relief           
          under section 6015.                                                         
               The liability for each of the taxable years 1989, 1991,                
          1992, and 1993 is from the assessment that respondent made for              
          each such year based upon the stipulated decision in the case for           
          the taxable years at issue.  The liability for the taxable year             
          1990 is from the unpaid tax shown due in the original 1990 joint            
          return, plus interest thereon as provided by law, which respon-             
          dent assessed, plus an additional assessment of $3,978 to which             
          petitioner and Mr. Monsour agreed after the examination of the              
          taxable years at issue began and before respondent issued the               
          notice for the taxable years at issue.                                      
          Burden of Proof                                                             
               The parties agree that petitioner bears the burden of prov-            

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