Apollo Overseas International, Inc. - Page 2

                                        -  -2                                           
                             Additions to Tax                                         
          Tax year                Sec.      Secs. 6653(a)(1)(A)/   Sec.          Sec. 
          ended     Deficiency   6651(a)       6653(a)         6653(a)(1)(B)    6661(a)
          1/31/88     $145,156    $36,289       $7,258              1           $36,289
          1/31/89      289,298     72,325       14,465             -0-           72,325
               1  Plus 50% of the interest that is computed on $145,156 for the       
          taxable year ended Jan. 31, 1988, at the time of assessment and/or          
          payment of tax.                                                             
          Tax year                   Addition to Tax         Penalty                  
          ended       Deficiency     Sec. 6651(a)         Sec. 6662(a)                
          1/31/90      $490,772        $122,693               $98,154                 

               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 Procedure, unless otherwise                 
               Some of the issues raised by the pleadings have been                   
          disposed of by agreement of the parties (including all issues               
          pertaining to the taxable year ended January 31, 1988 (fiscal               
          year 1988)), leaving for decision the amount of customs duties,             
          freight charges, and related fees paid by petitioner with respect           
          to its goods purchased for sale during each of the years here in            
          issue, which, when added to the agreed cost of purchases other              
          than these charges, results in cost of the goods purchased.  The            
          parties agree as to whether the additions to tax and penalty                
          apply to petitioner and that the amount of such additions to tax            
          and penalty will be computed under Rule 155.                                

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