Ernesto H. Monroy - Page 2

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          Unless otherwise indicated, 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.                                                                  
               After concessions, the issues for decision are:  (1) Whether           
          petitioner had unreported income in 1990 in the amount of                   
          $941,671; (2) whether petitioner had unreported income in 1991 in           
          the amount of $563,877; and (3) whether petitioner is liable for            
          the fraud penalty for 1990 and 1991.                                        
                                  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 Leon, Mexico.            
          Petitioner is a citizen of Mexico.  Petitioner married Maria del            
          Carmen Yurietta Valdes (Yurietta) in 1959; they had five                    
          children.  Petitioner and Yurietta were separated in 1974, and              
          Yurietta is not a party to this proceeding.                                 
               Petitioner filed Forms 1040, U.S. Individual Income Tax                
          Returns, for 1988 through 1991.  On those returns, petitioner               
          stated that he resided in San Antonio, Texas.  Petitioner claimed           
          single as his filing status.                                                
               On December 27, 1989, petitioner applied for a mortgage on             
          4 Morning Downs, a residence located in the "Dominion", an                  
          exclusive country club in San Antonio, Texas.  Petitioner                   
          purchased the home for $673,956, paying $5,302.65 as a down                 




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