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6653(b)(1) for 1988, and section 6651(f) for 1989. We hold for
respondent on all issues.
Background
Petitioner and his spouse Angela M. Campbell (Ms. Campbell)
filed joint Federal income tax returns for 1983 through 1986.
Despite demonstrated knowledge of the requirement to file tax
returns, petitioner and Ms. Campbell failed to file Federal
income tax returns for 1987 through 1989. Using the expenditure
method for reconstruction of income, respondent determined that
the gross income of petitioner and Ms. Campbell was $126,846,
$108,438, and $47,969 for 1987 through 1989, respectively.
Respondent determined that petitioner's community property share
for the respective years was $63,423, $54,219, and $23,984. On
June 15, 1995, petitioner petitioned the Court for a
redetermination of respondent's determination. Petitioner was
incarcerated at the Montgomery County jail in Conroe, Texas, when
he petitioned the Court.
On April 19, 1996, respondent filed a motion for continuance
of trial on the ground that petitioner was undergoing criminal
prosecution, and petitioner's criminal trial was scheduled to
commence on May 20, 1996. Contemporaneously, respondent filed a
motion to consolidate for trial, briefing, and Opinion
petitioner's case at docket number 10421-95 with Ms. Campbell's
case at docket number 10419-95. Petitioner's and Ms. Campbell's
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