William O. Harrison - Page 2

                                        - 2 -                                         

                       1989      179,964        44,991                                
                       1990       14,324        3,581                                 

             Unless stated otherwise, all section references are to the               
             Internal Revenue Code as in effect for the years in issue.               
             After concessions, the issue for decision is whether                     
             petitioners are liable for additions to tax under section                
             6651(a)(1) for failure to file timely income tax returns                 
             for 1988 and 1989.                                                       

                                  FINDINGS OF FACT                                    
                  Some of the facts have been stipulated and are so                   
             found.  The stipulation of facts and the exhibits attached               
             thereto are incorporated herein by this reference.                       
             Petitioners are husband and wife who filed joint individual              
             income tax returns for 1988, 1989, and 1990.  At the time                
             the petition was filed in this case, petitioners resided                 
             in Corpus Christi, Texas.  In this opinion, references to                
             petitioner are to Mr. William O. Harrison, Jr.                           
                  Petitioner received a bachelor's degree in 1967 from                
             Texas Christian University where he majored in history.  He              
             received a law degree in 1970 from the University of Texas               
             Law School where, among other courses, he took a tax course              
             and a required course in legal accounting.  After                        
             graduating from law school, petitioner was employed from                 
             1971 through 1975 by a law firm in Corpus Christi, Texas.                




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