Stanley P. Zurn - Page 3

          a fraud penalty or, alternatively, an accuracy-related penalty              
          for 1989; and (9) whether petitioner is liable for an addition to           
          tax for failure to timely file his 1989 Federal income tax                  
               For convenience, findings of fact and legal discussion are             
          being combined for related issues.  Petitioner resided in Los               
          Angeles, California, at the time the petition in this case was              
          filed.  Petitioner, a high school graduate, completed some                  
          college on a part-time basis.  Petitioner was employed by the               
          City of Los Angeles, Bureau of Street Maintenance, as a                     
          construction crew supervisor.  The job involved the use of heavy,           
          off-road paving and concrete equipment.  Petitioner retired from            
          his city job in 1980 and entered the real estate business.                  
               Petitioner was successful in the real estate business and              
          had accumulated in excess of 20 rental properties by the close of           
          Issue 1.  Whether Petitioner Failed To Include Income of $208,994           
          for 1986                                                                    
               Respondent determined, for 1986, that petitioner's income              
          should be increased by $325,994 attributable to unexplained bank            
          deposits, as follows:                                                       

          1 The parties’ stipulation of facts and exhibits are                        
          incorporated herein by this reference.                                      

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