Maureen Monsour - Page 36

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          Mr. Monsour a return for each of the taxable years at issue and             
          was jointly and severally liable for the tax shown due in each of           
          those returns and for any deficiency in, addition to, and penalty           
          on the tax for each of those years to which petitioner and Mr.              
          Monsour and respondent agreed and which the Court sustained in              
          the stipulated decision in the case for the taxable years at                
          issue.32                                                                    
               Based upon our examination of the entire record before us,             
          we find that petitioner has failed to carry her burden of estab-            
          lishing that she did not participate meaningfully in the case for           
          the taxable years at issue and that the stipulated decision in              
          that case, which did not grant petitioner relief from joint and             
          several liability, is not conclusive in the instant case.  See              
          sec. 6015(g)(2).  On that record, we hold that section 6015(g)(2)           
          precludes petitioner from the relief that she claims under sec-             
          tion 6015(b) and (f).  See Thurner v. Commissioner, 121 T.C. 43,            
          51-52 (2003).                                                               


               31(...continued)                                                       
          nor the joint returns for the taxable years 1991, 1992, and 1993            
          support petitioner’s contention that the determinations relating            
          to petitioner’s law practice bank account were the only determi-            
          nations in the notice for the taxable years at issue that “af-              
          fected Petitioner directly”.  We have found that respondent made            
          determinations in that notice of omitted income relating to the             
          joint bank accounts of petitioner and Mr. Monsour and relating to           
          petitioner’s separate bank account.  At a minimum, such determi-            
          nations also “affected Petitioner directly”.                                
               32See supra note 28.                                                   





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