- 39 -
of those issues (except the minor issue involving Peti-
tioner’s law office income adjustment) involved only
Petitioner’s husband. Clearly, all of the understate-
ments could only be attributable to the husband’s activ-
ities, namely his investments or omissions from income,
since only he was involved in those activities.
Respondent counters that
a portion of the deficiencies for two years were from
unreported income from petitioner’s law practice and not
solely from Dr. Monsour. Also, for three years of
deficiencies, it is more likely than not that unreported
income reflected in deposits to joint accounts of peti-
tioner and Dr. Monsour and single accounts in the name
of petitioner are part of the deficiencies.
* * * [Moreover,] there is no evidence as to the
amount of an understatement of tax now due for a partic-
ular year as to a specific erroneous item of her hus-
band. * * *
The determinations about which we are aware34 that respondent
made in the notice for the taxable years at issue relate to the
joint bank accounts of petitioner and Mr. Monsour, petitioner’s
separate bank account, petitioner’s law practice bank account,
Monsour Medical Center, Laurel Valley Farms, the Three Crowns
Hotel, Azure Tides, Inc., Georgetown Square,35 the Three Crowns
34See supra notes 9 through 12 and 18 and accompanying text.
35We have found that respondent conceded respondent’s deter-
mination of omitted income with respect to Georgetown Square for
one or more of the taxable years 1989, 1991, 1992, and 1993 not
disclosed by the record. In the notice for the taxable years at
issue, respondent also made a determination of an erroneous
deduction with respect to Georgetown Square for one or more of
the taxable years 1989, 1991, 1992, and 1993 not disclosed by the
record. Hereinafter, our references to the determination with
respect to Georgetown Square shall be to a determination of an
erroneous deduction for one or more of those years.
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