Maureen Monsour - Page 57

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          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              






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