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Record in the Instant Case
In support of her position in the instant case, petitioner
relies principally on her own testimony and the testimony of Mr.
Monsour. We did not find the testimony of petitioner and Mr.
Monsour to be credible in certain material respects. We shall
not rely on any such testimony to support petitioner’s position
in the instant case.
The testimony of petitioner and Mr. Monsour on which we are
willing to rely and the documentary evidence16 that petitioner
introduced into the record create a record that presents signifi-
cant proof problems for petitioner. For example, the record does
not establish (1) the taxable year or years (i.e., 1989, 1991,
1992, and/or 1993)17 to which each of the determinations about
which we are aware18 pertains and (2) the portion, if any, of the
16Petitioner did not proffer into evidence certain documen-
tary evidence (e.g., the notice for the taxable years at issue)
that is material to petitioner’s position in the instant case.
17The parties stipulated that 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
respondent 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.
18Although the record shows that respondent made certain
determinations in the notice for the taxable years at issue with
respect to the taxable years 1989, 1991, 1992, and 1993, the
record does not establish whether those were the only determina-
tions that respondent made in that notice. See supra note 9.
Except for a determination of omitted income with respect to
(continued...)
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