- 57 -
has failed to establish that she did not know, and had no reason
to know, of the transactions relating to the joint bank accounts
of petitioner and Mr. Monsour, petitioner’s separate bank account,
and petitioner’s law practice bank account that we assume arguendo
gave rise to a portion or all of an understatement for one or more
of the taxable years 1989, 1991, 1992, and 1993.
As for any determination by respondent of omitted income with
respect to Monsour Medical Center, petitioner does not dispute
that the record establishes: (1) Respondent made a determination
of omitted income in one or more of the taxable years 1989, 1991,
1992, and 1993 with respect to Monsour Medical Center; (2) Mr.
Teitelbaum, legal counsel for Monsour Medical Center, sent to
petitioner a copy of his response to the subpoena that respondent
served on Monsour Medical Center in the case for the taxable years
at issue in order to determine whether there was any omitted
income with respect to that entity; and (3) no other facts rele-
vant to such omitted income. On the record before us, we find
that petitioner has failed to establish that she did not know, and
had no reason to know, of any transaction relating to Monsour
Medical Center that we assume arguendo gave rise to a portion or
all of an understatement for one or more of the taxable years
1989, 1991, 1992, and 1993.
We turn now to the determinations of erroneous deductions
relating to Laurel Valley Farms, the Three Crowns Hotel, Azure
Page: Previous 47 48 49 50 51 52 53 54 55 56 57 58 59 60 61 62 63 64 65 66 NextLast modified: May 25, 2011