Guillermo Baez Espinosa - Page 4

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          taxable years 1987 through 1991, his Federal income tax returns             
          were due on June 15 of the year following the close of the                  
          taxable year.  Sec. 6072(c).  As of November 13, 1992, petitioner           
          had not filed any Federal income tax returns for the years in               
          issue.  On that date, respondent mailed a letter to petitioner              
          asking him if he had filed returns and, if he had not,                      
          instructing him to file returns or otherwise respond.  That                 
          letter also stated that, if petitioner did not respond by                   
          December 1, 1992, respondent would file substitute returns for              
          him.  Petitioner did not respond, and on January 12, 1993,                  
          respondent again wrote petitioner with the same request, adding             
          that, if there was no response within 20 days, "your tax                    
          liability [will be determined] based on the information we have."           
          Again petitioner did not respond.  On February 3, 1993,                     
          respondent notified petitioner that respondent had filed                    
          substitute returns for the taxable years 1987 through 1991.  On             
          March 23, 1993, respondent informed petitioner that the                     
          substituted returns were computed without the benefit of any                
               On October 7, 1993, petitioner submitted Federal income tax            
          returns for all the years in issue.  The returns reflected the              
          net losses from the rental properties described above.  Each                
          return contained an election pursuant to section 871(d), to treat           

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