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Winschel and/or Mr. Monsour or otherwise having meaningfully
participated in that case.29
Petitioner relies on Mr. Laubach’s testimony, the 1991 joint
return, the 1992 joint return, and the 1993 joint return to
support her contention that only “two (2) years of allegedly
omitted attorney income” directly affected petitioner in the case
for the taxable years at issue, viz., respondent’s determinations
in the notice that there was income relating to petitioner’s law
practice bank account that petitioner and Mr. Monsour did not
report in their joint returns for two of the three taxable years
1991, 1992, and 1993.30 Our resolution of the question whether
petitioner participated meaningfully in the case for the taxable
years at issue within the meaning of section 6015(g)(2) does not
depend on how many determinations in the notice for those years
“affected Petitioner directly”.31 Petitioner filed jointly with
29It is noteworthy that Mr. Teitelbaum, legal counsel for
Monsour Medical Center, sent to petitioner, and not to Mr.
Monsour and not even to Mr. Monsour and petitioner, a copy of his
response to the subpoena that respondent served on Monsour
Medical Center in the case for the taxable years at issue with
respect to a determination of omitted interest income that
respondent made in the notice for the taxable years at issue for
one or more of the taxable years 1989, 1991, 1992, and 1993 with
respect to that entity.
30The record does not establish, and petitioner does not
even allege, for which two of the three taxable years 1991, 1992,
and 1993 respondent made the determination of unreported income
relating to petitioner’s law practice bank account.
31In any event, we find that neither Mr. Laubach’s testimony
(continued...)
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