John B. Mathers, Sr. - Page 2

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          Respondent's amended answer asserted the delinquency and                    
          negligence additions to tax under sections 6651 and 6653(a),                
          respectively, in the alternative to the fraud addition to tax.              
          Unless otherwise noted, all section references are to the                   
          Internal Revenue Code in effect for the years in issue, and all             
          Rule references are to the Tax Court Rules of Practice and                  
               After concessions, the issues remaining for decision are:              
          (1) Whether payments received by petitioner constituted loan                
          repayments or constructive dividends; (2) whether payments made             
          to petitioner's son constituted constructive dividends to                   
          petitioner; (3) whether petitioner is liable for the fraud                  
          addition to tax, or, in the alternative, for the delinquency and            
          negligence additions to tax; and (4) whether petitioner is liable           
          for the addition to tax for failure to pay estimated taxes.                 

                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated, and the stipulated             
          facts are incorporated in our findings by this reference.  At the           
          time the petition was filed, petitioner resided in Mobile,                  
               Petitioner graduated from high school and attended 2 years             
          of college.  Petitioner worked in the finance industry before               
          entering the retail furniture business in 1960.                             

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