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that a requesting spouse did not satisfy section 6015(f), the
Court has relied on, inter alia, its findings that such spouse did
not satisfy section 6015(b)(1)(C). See, e.g., Butler v. Commis-
sioner, 114 T.C. at 284-286, 292.45
The determinations about which we are aware46 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, the Three Crowns
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.47 On the
45See also Bartak v. Commissioner, T.C. Memo. 2004-83; Doyel
v. Commissioner, T.C. Memo. 2004-35.
46See supra notes 9 through 12 and 18.
47Nor does the record establish the nature of the determina-
tions (i.e., omitted income or erroneous deductions) that respon-
dent 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 American Supply and MFS Lifetime. MFS Lifetime, in which Mr.
Monsour invested, was a mutual fund. It thus appears that any
determination by respondent relating to MFS Lifetime might have
been a determination of omitted income. However, petitioner has
failed to establish, and the record does not provide a basis for
(continued...)
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