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Hotel Back Court, American Supply, and MFS Lifetime. As discussed
above, the record does not establish, inter alia, (1) the taxable
year or years (i.e., 1989, 1991, 1992, and/or 1993) to which each
of the determinations about which we are aware pertains and
(2) the portion, if any, of the understatement for each of those
years that is attributable to each such determination. On the
record before us, we are unable to find whether or not each of
respondent’s determinations about which we are aware relates to an
erroneous item under section 6015(b)(1)(B) that gave rise to a
portion or all of an understatement for one or more of the taxable
years 1989, 1991, 1992, and 1993.
Assuming arguendo that each of respondent’s determinations
about which we are aware had related to such an erroneous item, we
turn first to petitioner’s contention that the only such erroneous
items that involved her were with respect to petitioner’s law
practice bank account. We have found that, in addition to the
determinations relating to petitioner’s law practice bank account,
the determinations relating to the joint bank accounts of peti-
tioner and Mr. Monsour and petitioner’s separate bank account
affected petitioner directly.36 On the record before us, we find
that petitioner has failed to establish that the determinations
with respect to petitioner’s law practice bank account, the joint
bank accounts of petitioner and Mr. Monsour, and petitioner’s
36See supra note 31.
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