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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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