Maureen Monsour - Page 56

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          record before us, we are unable to find whether or not each of              
          respondent’s determinations about which we are aware 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 given rise to a portion or all of an           
          understatement for one or more of the taxable years 1989, 1991,             
          1992, and 1993, we turn first to the determinations of omitted              
          income relating to the joint bank accounts of petitioner and Mr.            
          Monsour, petitioner’s separate bank account, petitioner’s law               
          practice bank account, and Monsour Medical Center.  Petitioner              
          concedes that she was aware of the omitted income with respect to           
          her law practice bank account.  However, she argues that she did            
          not know, and had no reason to know, of the other items of omitted          
          income.  On the record before us, we reject that argument.  As for          
          the determinations of omitted income relating to the joint bank             
          accounts of petitioner and Mr. Monsour and petitioner’s separate            
          bank account, petitioner does not dispute that the record estab-            
          lishes:  (1) Petitioner’s name was on each of those accounts;               
          (2) respondent made determinations of omitted income with respect           
          to each such account; and (3) no other facts relevant to such               
          omitted income.  On the record before us, we find that petitioner           

               47(...continued)                                                       
          us to find, that any determination by respondent relating to MFS            
          Lifetime was a determination of omitted income.                             





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