Leslie R. Barth - Page 5

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                  During the years in issue, petitioner maintained a home in                            
            Fairfield, Connecticut, that had 16 rooms and was situated on                               
            10.6 acres of land.  Petitioner acquired a collection of                                    
            automobiles.  As of 1979, petitioner maintained at his residence                            
            in Connecticut no fewer than 10 automobiles, including a 1979                               
            Rolls Royce, a 1977 Jaguar, two 1972 Ferraris, and 5 Mercedes                               
            ranging from the 1971 model to a 1979 model.  Petitioner                                    
            registered a 1975 Pontiac in his name, but all of the other                                 
            automobiles were registered in the name of International                                    
            Automobiles, Ltd., an entity that purported to be a business                                
            conducted by petitioner or by petitioner and Ms. Barth as                                   
            partners, but which conducted little or no actual business                                  
                  During the years in issue, petitioner submitted financial                             
            statements to various institutions.  On financial statements                                
            dated September 29, 1977, October 10, 1978, and April 19, 1979,                             
            petitioner represented that his compensation from his law firm                              
            was $225,000.  On two financial statements dated September 19,                              
            1980, he represented that his compensation from the law firm was                            
            $250,000.  In March 1980, petitioner signed a Form 1120S, U.S.                              
            Small Business Corporation Income Tax Return, for his law firm.                             
            That return showed petitioner's compensation as $700,000.                                   
            Petitioner, however, did not file that return.                                              
                  Petitioner did not file timely Federal income tax returns                             
            for the years in issue for himself, for the law firm, or for                                

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