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separate bank account related to erroneous items of Mr. Monsour
under section 6015(b)(1)(B).
We turn now to petitioner’s contention that each of the
determinations relating to Monsour Medical Center, Laurel Valley
Farms, the Three Crowns Hotel, Azure Tides, Inc., Georgetown
Square, the Three Crowns Hotel Back Court, American Supply, and
MFS Lifetime did not involve her. Assuming arguendo that those
determinations had related to erroneous items of Mr. Monsour that
gave rise to a portion or all of an understatement for one or more
of the taxable years 1989, 1991, 1992, and 1993 (assumed erroneous
items of Mr. Monsour), on the record before us, we find that
petitioner has failed to establish (1) the taxable year or years
(i.e., 1989, 1991, 1992, and/or 1993) to which such assumed
erroneous items of Mr. Monsour pertain and (2) the portion of the
understatement for each of those years that is attributable to
such assumed erroneous items. We have found that petitioner has
failed to establish that the determinations relating to peti-
tioner’s law practice bank account, the joint bank accounts of
petitioner and Mr. Monsour, and petitioner’s separate bank account
related to erroneous items of Mr. Monsour under section
6015(b)(1)(B). Consequently, those determinations may have
related to erroneous items of petitioner that gave rise to a
portion or all of an understatement for one or more of the taxable
years 1989, 1991, 1992, and 1993.
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